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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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