Della H. Knorr and Duane J. Knorr - Page 21

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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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