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Consequently, this factor weighs against granting relief to
petitioner.
3. Economic Hardship
Respondent contends that petitioner does not satisfy the
economic hardship test because she admitted that she is able to
pay her reasonable basic living expenses with her income.
Respondent further contends that petitioner failed to submit any
documentation of her monthly expenses to support her contention
that she would suffer economic hardship.
Petitioner admitted at trial that she told the Appeals
officer that her income was sufficient to meet her reasonable
living allowances. Given that admission, and in the absence of
documentation to the contrary, the record does not support a
finding that petitioner will suffer economic hardship if she is
not relieved from joint and several liability.
Consequently, this factor weighs against granting relief to
petitioner.
D. Conclusion
After considering all of the facts and circumstances, we
find that it would not be inequitable to hold petitioner liable
for payment of the outstanding liability. Thus, we hold that
respondent did not abuse his discretion in denying petitioner
equitable relief from joint and several liability under section
6015(f).
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Last modified: May 25, 2011