Teresa J. Fox - Page 8

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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.            
               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.             

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