- 31 - value of $350,000 and further related that the condominium was encumbered by a $60,000 mortgage. Petitioner was also entitled to receive $4,400 per month in nontaxable payments from Levy. Petitioner earned $21,600 as a real estate agent for 2003. Additionally, by 2002 all three of her children had reached majority and were no longer her dependents. We conclude that petitioner has failed to meet her burden of showing that she would suffer economic hardship if relief were not granted to her for 1991 through 1999. See Knorr v. Commissioner, supra (noting, among other things, that requesting spouse’s situation was dissimilar to other cases where taxpayers were living at or near poverty level and proved they would suffer economic hardship without granting of relief); Ogonoski v. Commissioner, T.C. Memo. 2004-52 (holding that economic hardship factor weighed against taxpayer because she failed to introduce sufficient current financial information on that factor); Castle v. Commissioner, T.C. Memo. 2002-142 (holding that taxpayer failed to establish economic hardship because she did not offer evidence regarding pertinent factors in determining her reasonable basic living expenses). This lack of economic hardship weighs against granting petitioner relief for 1991 through 1999. 4. Knowledge or Reason To Know Factor In the case of a liability that was reported but not paid, the fact that the requesting spouse did not know and had noPage: Previous 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 Next
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