Carolyn A. Glenn - Page 15

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          Mr. Glenn were divorced on November 13, 2002.  This factor weighs           
          in favor of granting relief to petitioner.                                  
         2.  Economic Hardship                                                        
              Respondent contends that petitioner offered no evidence that            
         she would suffer economic hardship if relief were denied.                    
         Pursuant to section 301.6343-1(b)(4)(ii), Proced. & Admin. Regs.,            
         economic hardship exists if a levy will cause a taxpayer to be               
         unable to pay his/her reasonable basic living expenses.                      
         Respondent maintains that respondent’s collection activity would             
         not leave petitioner unable to pay her basic living expenses.10              


          10Sec. 301.6343-1(b)(4)(ii), Proced. & Admin. Regs.,                        
          provides:                                                                   
               (ii) Information from taxpayer.  In determining a reasonable           
               amount for basic living expenses the director will consider            
               any information provided by the taxpayer including–-                   
                    (A) The taxpayer’s age, employment status and history,            
                    ability to earn, number of dependents, and status as a            
                    dependent of someone else;                                        
                    (B) The amount reasonably necessary for food, clothing,           
                    housing, (including utilities, home-owner insurance,              
                    home-owner dues, and the like), medical expenses                  
                    (including health insurance), transportation, current             
                    tax payments (including federal, state, and local),               
                    alimony, child support, or other court-ordered                    
                    payments, and expenses necessary to the taxpayer’s                
                    production of income (such as dues for a trade union or           
                    professional organization, or child care payments which           
                    allow the taxpayer to be gainfully employed);                     
                    (C) The cost of living in the geographic area in which            
                    the taxpayer resides;                                             
                    (D) The amount of property exempt from levy which is              
                    available to pay the taxpayer’s expenses;                         
                                                             (continued...)           




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