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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 no
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