Carolyn A. Glenn - Page 16

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         In addition, respondent asserts that petitioner provided no                  
         documentation to contradict these contentions or to demonstrate              
         an economic hardship.                                                        
              On Form 12510, Questionnaire for Requesting Spouse,                     
         petitioner stated her necessary monthly living expenses as                   
         approximately $3,136 per month.  Also on Form 12510, petitioner              
         stated her total monthly income as approximately $3,500,                     
         consisting of her earned wages of $2,400 per month and child                 
         support of $1,100 received per month.  On the basis of these                 
         facts, respondent determined that petitioner would not suffer                
         economic hardship if relief was not granted.  Petitioner did not             
         supply any evidence at trial to contradict the above facts or the            
         determination of respondent; therefore, we find that petitioner              
         will not suffer economic hardship if relief is not granted.  This            
         factor favors denying relief.                                                
         3.  Knowledge or Reason To Know                                              
              In the case of an income tax liability that arose from a                
         deficiency, the fact that the requesting spouse did not know and             
         had no reason to know of the item giving rise to the deficiency              


         10(...continued)                                                             
                    (E) Any extraordinary circumstances such as special               
                    education expenses, a medical catastrophe, or natural             
                    disaster; and                                                     
                    (F) Any other factor that the taxpayer claims bears on            
                    economic hardship and brings to the attention of the              
                    director.                                                         




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