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asserts that these factors weigh against granting relief to
petitioner. We now address each of these factors separately.
1. Economic Hardship
Respondent contends that petitioner offered no evidence to
show that she would suffer an economic hardship if relief were
denied. Respondent asserts that pursuant to section 301.6343-
1(b)(4)(ii), Proced. & Admin. Regs., an economic hardship exists
if satisfaction of 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.5 In
5Sec. 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;
(continued...)
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