Janet H. Krasner, Petitioner, and Paul Krasner , Intervenor - Page 51

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          reducing the amount that they were spending on household and                
          other items.  We do not believe petitioner’s version of the                 
          events that transpired on the day she signed the 1998 joint                 
          return.26  We believe Mr. Krasner’s testimony about those events.           
               On the record before us, we find that petitioner has failed            
          to carry her burden of establishing that the knowledge or reason            
          to know element set forth in section 4.02(1)(b) of Revenue                  
          Procedure 2000-15 is present here.                                          
               With respect to the economic hardship element set forth in             
          section 4.02(1)(c) of Revenue Procedure 2000-15,27 petitioner               

               26In petitioner’s Form 8857 filed around Jan. 15, 2001, and            
          in petitioner’s Form 886-A filed between Aug. 31 and Oct. 26,               
          2001, petitioner denied that she signed the 1998 joint return.              
          It was only in petitioner’s November 1, 2001 letter to respondent           
          that petitioner stopped denying that she signed the 1998 joint              
          return and indicated that she did not remember signing that                 
          return.  In petitioner’s November 7, 2003 letter to respondent,             
          petitioner again contended that she did “not have immediate                 
          recollection of signing this [1998 joint] return”.                          
               27In determining whether a requesting spouse will suffer               
          economic hardship, sec. 4.02(1)(c) of Revenue Procedure 2000-15,            
          to which sec. 4.03(1)(b) of that revenue procedure refers,                  
          requires reliance on rules similar to those provided in sec.                
          301.6343-1(b)(4), Proced. & Admin. Regs.  Sec.                              
          301.6343-1(b)(4)(i), Proced. & Admin. Regs., generally provides             
          that an individual suffers an economic hardship if the individual           
          is unable to pay his or her reasonable basic living expenses.               
          Sec. 301.6343-1(b)(4), Proced. & Admin. Regs., provides in                  
          pertinent part:                                                             
                    (ii) Information from taxpayer.--In determining a                 
               reasonable amount for basic living expenses the direc-                 
               tor will consider any information provided by the                      
               taxpayer including--                                                   
                         (A) The taxpayer's age, employment status and                
                                                             (continued...)           




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