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$2 million.30 Respondent contends that at that time that liabil-
ity was approximately $2 million. Suffice it to say that the
parties agree that at the time of the trial the total liability
with respect to petitioner’s taxable year 1982 was at least $2
million. Moreover, interest as provided by law continues to
accrue thereafter with the passage of time. See sec. 6601.
Thus, the total liability for taxable year 1982 continues to
increase with the passage of time (1982 total liability).
Respondent maintains, and petitioner does not dispute, that,
because petitioner and Mr. Korchak were still married at the time
of the trial, it is appropriate to consider the income, the
assets, and the liabilities of both of them in determining
whether petitioner would suffer an economic hardship if she were
required to pay the 1982 total liability. The parties agree that
at the time of the trial the total value of the assets of peti-
tioner and Mr. Korchak was $1,972,169. The parties also agree
that at that time the residence in which petitioner and Mr.
Korchak were living that petitioner owned was subject to liabili-
ties totaling $139,000.31
30In petitioner’s December 15, 2004 memorandum that she
submitted to respondent during the consideration by respondent’s
examiner of petitioner’s claim under sec. 6015, petitioner
indicated that, as of Dec. 13, 2004, the total liability with
respect to her taxable year 1982 exceeded $2.5 million.
31See supra note 19.
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