Francenia M. Griffin - Page 15

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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.,                         
               (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;                                             

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