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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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