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tax liability in whole or in part will cause the taxpayer to be
unable to pay her reasonable basic living expenses.8 Sec.
301.6343-1(b)(4), Proced. & Admin. Regs.
In 2000, petitioner filed a Form 433-A with respondent.
Petitioner reported on the Form 433-A that she was employed by
the Puget Sound Blood Center as a technician, with an annual
salary of approximately $25,600.9 Petitioner reported her
monthly income as $2,133 and her monthly expenses as $2,078.
Petitioner’s stated monthly expenses included housing and utility
expenses of $1,398, transportation expenses of $425, and health
care expenses of $60. Petitioner also included $195 of monthly
credit card payments in her expenses but testified at trial she
8Sec. 301.6343-1(b)(4)(ii), Proced. & Admin. Regs., lists
factors that will be considered in determining a reasonable
amount for basic living expenses. These factors include the
taxpayer’s age, employment status and history, ability to earn,
number of dependents, extraordinary circumstances, and any other
factor that the taxpayer claims bears on economic hardship and
brings to the attention of the director.
9Petitioner did not include a Form W-2, Wage and Tax
Statement, with her Form 433-A from the Blood Center. She
provided only a pay stub that showed her net pay for the pay
period ending July 22, 2000 (the length of this pay period is not
provided), and some year-to-date information regarding her
salary.
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