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property exempt from levy which is available to pay the
taxpayer’s expenses; (e) any extraordinary circumstances such as
special education expenses, a medical catastrophe, or a natural
disaster; and (f) any other factor that the taxpayer claims bears
on economic hardship and brings to the Commissioner’s attention.
Id.
The parties dispute whether payment of the tax at issue
would be an economic hardship for petitioner. Petitioner
estimated the monthly amounts of several necessary living
expenses listed in section 301.6343-1(b)(4)(ii), Proced. & Admin.
Regs., e.g., $400 for food, $120 for gasoline, and $10 for
clothing. According to her estimates, her expenses equaled or
exceeded her income. However, it does not appear that petitioner
always incurred the amounts of expenses she listed. For example,
she testified that she spent the amounts indicated for gasoline
and clothing if she could afford to spend that much. Thus, we
think petitioner overstated her monthly expenses somewhat.
Petitioner was 42 years old at the time of trial and
apparently she will be able to be employed for many more years.
If relief is not granted, petitioner will remain liable for
paying $8,261 plus related interest. We conclude that this
factor is neutral.5
5 Respondent contends, in effect, that petitioner’s
expenses for her son were not reasonable basic living expenses.
(continued...)
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