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to know about Mr. Lathrop’s unemployment compensation or
nonemployee compensation for the year at issue.
As discussed earlier, petitioner had actual knowledge of Mr.
Lathrop’s unemployment and nonemployee compensation.
Petitioner’s actual knowledge is a strong factor weighing against
relief, which can be overcome only if the factors in favor of
equitable relief are particularly compelling.
Petitioner contends in her petition to this Court that she
would experience economic hardship if she were forced to pay the
tax liability for the year at issue. A taxpayer might experience
economic hardship if he or she were unable to pay basic
reasonable living expenses. Sec. 301.6343-1(b)(4)(i), Proced. &
Admin. Regs. It is the taxpayer’s burden to show both that the
expenses qualify and that they are reasonable. Monsour v.
Commissioner, T.C. Memo. 2004-190. Despite her assertion that
paying the tax liability would cause her to experience economic
hardship, petitioner provided no evidence at trial that she would
be unable to pay basic living expenses if she were held liable
for the deficiency. The Court fails to see, and petitioner has
not established, that she would suffer economic hardship if her
request for relief from joint liability were denied. This factor
weighs against granting petitioner relief.
On the basis of the facts and circumstances in this case,
including the factors set forth in Rev. Proc. 2000-15, supra, the
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