Rhea Ione Supplee Negoescu - Page 11

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          This factor is neutral.                                                       
               Later compliance:  Negoescu and Supplee did not make full                
          and timely payment for their 1993 tax bill.  Though Negoescu did              
          have money withheld from her job at the hospital, and though she              
          also paid an additional $833 with the return, she was still short             
          $747.  The full amount, including interest and penalties, was not             
          paid until 1995, when her expected refund for 1994 was credited               
          to the balance due.  This means that she has not consistently                 
          complied with the Federal tax laws by making timely payments.                 
          This factor weighs against her.                                               
               Knowledge:  As we mentioned above, Negoescu knew when she                
          signed the 1991 and 1992 tax returns that the liabilities shown               
          on those returns would not be paid.  This factor also weighs                  
          against her.  Furthermore, the revenue procedure states, “This is             
          an extremely strong factor weighing against relief,” making this              
          factor more important than the others.  Rev. Proc. 2000-15, sec.              
          4.03(2)(b), 2000-1 C.B. 447.                                                  
               Economic Hardship:  The factor forces us to ask whether                  
          Negoescu would be able to pay her reasonable basic living                     
          expenses if she does not receive relief.  Alt, 119 T.C. at 314-               
          315.  While she claims that her monthly expenses are more than                
          her monthly income, she did not show any documentary evidence                 
          that this is true.  She testified that her monthly wages from her             
          job at the hospital were about $2400 a month.  She also received              






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