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and the amount reasonably necessary for basic living expenses.
See sec. 301.6343-1(b)(4)(ii), Proced. & Admin. Regs.
After respondent issued the notice of determination,
intervenor successfully appealed a portion of the final judgment,
and, as a result, an amended final judgment was filed in February
2003. As set forth in the amended final judgment, petitioner was
awarded unencumbered assets with a value in excess of $532,000 as
of April 15, 1998, and intervenor was required, inter alia, to
pay to petitioner more than $114,000 with respect to previously
ordered support and an equalizer payment. Among the unencumbered
assets awarded to petitioner was the Stonegate residence, which,
as of the time of trial on February 2, 2004, had appreciated to a
value in excess of $650,000. Moreover, as of the time of trial,
intervenor was paying to petitioner $700 per month to satisfy his
debt to her as well as approximately $1,520 per month for child
support, and petitioner was employed as a personal trainer and
was earning approximately $300 per week (excluding any earnings
from private personal training clients).
Petitioner did not present evidence of her reasonable basic
living expenses or otherwise show economic hardship. She
asserted that liens in excess of $350,000 have been placed on the
Stonegate residence since the time of her divorce from
intervenor. It is unclear whether the liens that she had in mind
included liens for the tax liabilities in dispute, but, in any
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