Joan Phyllis Levy - Page 31

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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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