Ruth E. Neal - Page 19

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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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