Maureen Monsour - Page 53

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                    (F) Any other factor that the taxpayer claims bears               
               on economic hardship and brings to the attention of the                
               director.                                                              
          Sec. 301.6343-1(b)(4)(ii), Proced. & Admin. Regs.                           
               Petitioner presented no evidence as to the nature or the               
          amounts of the bills that she claims she will be unable to pay if           
          she is not granted relief in this case.  On the record before us,           
          we find that petitioner has failed to carry her burden of estab-            
          lishing that the expenses claimed by petitioner (i.e., expenses             
          for bills) qualify as basic living expenses within the meaning of           
          section 301.6343-1(b)(4), Proced. & Admin. Regs.  Assuming                  
          arguendo that the bills claimed by petitioner qualify as basic              
          living expenses under that section, on the instant record, we find          
          that petitioner has failed to carry her burden of establishing              
          that the amounts of her claimed bills are reasonable.  Assuming             
          arguendo that the amount of the bills claimed by petitioner                 
          qualify as a reasonable amount for basic living expenses, we have           
          found that Mr. Monsour, and not petitioner, signed the checks to            
          pay at least certain of the bills relating to the residence of              
          petitioner and Mr. Monsour.44  On the record before us, we find             
          that petitioner has failed to carry her burden of establishing              
          that she will suffer an economic hardship if the Court were to              
          deny her relief under section 6015(f).  On that record, we further          

               44Mr. Monsour also signed checks with respect to Mr.                   
          Monsour’s investments as well as checks with respect to the joint           
          investments of petitioner and Mr. Monsour.                                  




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