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responsibility she has to care for and support her 40-year-old
schizophrenic son.
Petitioner has not established that she will suffer economic
hardship if relief is not granted. Respondent repeatedly
requested copies of current income information and current
financial information. Petitioner failed to provide this
information. The record demonstrates that petitioner had income
in excess of $200,000 from stock sales for the years 1996, 1998,
1999, and 2000. Petitioner contends that she sold the stocks in
1996 and 1999 to supplement her living expenses. However,
petitioner’s unfiled separate tax return reflects income prior to
her stock sales in excess of $242,000. In addition, at the time
of her request for relief, petitioner owned the property that she
purchased in Florida for $450,000. Petitioner also jointly owned
a house in Virginia and four rental properties in south Florida.
Further, the fact that petitioner did not provide any financial
information as requested supports a finding that respondent did
not abuse his discretion in concluding petitioner would not
suffer economic hardship. See Orum v. Commissioner, 123 T.C. 1,
13 (2004), affd. 412 F.3d 819 (7th Cir. 2005). Thus, petitioner
has failed to satisfy each of the three factors under Rev. Proc.
2000-15, sec. 4.02, and therefore does not qualify for equitable
relief under that section.
Where relief is not available under Rev. Proc. 2000-15, sec.
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