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petitioner as having had constructive knowledge of the unpaid
taxes relating to Alimam’s income.
Economic Hardship
Generally, economic hardship for purposes of section 6015(f)
is defined as the inability to meet “basic living expenses.” Alt
v. Commissioner, 101 Fed. Appx. 34, 44 (6th Cir. 2004), affg. 119
T.C. Memo. 306 (2002) (citing sec. 301.6343-1(b)(4), Proced. &
Admin. Regs).4
Petitioner argues that in spite of the salary she receives
as a medical doctor, she would suffer economic hardship if not
granted equitable relief herein. Petitioner notes that she
supports her youngest child and her two older children, that each
month she just breaks even with her finances, and that she has a
poor credit rating.
Although for many years petitioner has experienced financial
problems as the result of Alimam’s conduct and although
petitioner does not have any significant equity in any assets,
the facts before us are inconclusive as to the degree to which
petitioner would suffer economic hardship if she were denied
4 Sec. 301.6343-1(b)(4), Proced. & Admin. Regs., provides--
Economic hardship--(i) General rule. The levy is
creating an economic hardship due to the financial condition
of an individual taxpayer. This condition applies if
satisfaction of the levy in whole or in part will cause an
individual taxpayer to be unable to pay his or her
reasonable basic living expenses.
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