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to the second factor, the taxpayer must show that he or she would
be unable to pay basic reasonable living expenses if relief were
not granted. Monsour v. Commissioner, T.C. Memo. 2004-190.
Being unable to pay basic reasonable living expenses would amount
to economic hardship. Sec. 301.6343-1(b)(4)(i), Proced. & Admin.
Regs. Petitioner has not established that denial of her request
for relief would result in economic hardship. She was gainfully
employed, she had no dependents to support, and, in 1999,
petitioner’s spouse had quitclaimed his interest in their Murray,
Utah, home. In the divorce decree, petitioner was awarded
$27,500, which represented all of the proceeds from the sale of
that home. Additionally, the divorce decree ordered the former
spouse to pay petitioner alimony of “not less than $300 per
month” until either her death, remarriage, or cohabitation with
an adult male who was not a blood relative. The Court fails to
see, and petitioner has not established, that she would suffer
economic hardship if her request for relief from joint liability
is denied.
As to the third factor, the Court has held that petitioner,
particularly in light of her educational background and chosen
vocation, knew or should have known that Mr. Clark’s bookkeeping
was deficient. Moreover, petitioner received direct deposits,
both in her personal account and her joint account with Mr.
Clark, of unreported gross income during each of the years at
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