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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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