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taxpayer’s expenses; (5) any extraordinary circumstances such as
special education expenses, a medical catastrophe, or a natural
disaster; and (6) any other factor that the taxpayer claims bears
on economic hardship. See sec. 301.6343-1(b)(4)(ii), Proced. &
Admin. Regs.
In the instant case, the outstanding taxes, additions to
tax, and assessed interest for the 3 years in issue totaled
approximately $13,182 as of the date of trial. Petitioner
contends that she will suffer a substantial economic hardship if
she is not relieved of liability for this sum. Petitioner cites
her work as a sales clerk at Capretto Shoes while raising two
young children without support from Mr. Barrera due to his
imprisonment, her monthly mortgage payment, and the children’s
daycare expenses in support of her contention.
On the record before us, we do not think that petitioner has
provided evidence sufficient to support a finding of economic
hardship. Petitioner provided no information about her household
income and expenses in either the request for innocent spouse
relief or the questionnaire she submitted to respondent. At
trial, petitioner testified with specificity only with respect to
her monthly mortgage payment of $1,000 (not including taxes and
insurance), preschool expenses of $400 a month for her son
(although this expense was expected to end the following school
year when her son starts kindergarten), and payments to a live-in
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