Suzanne E. Barrera, a.k.a. Suzanne E. Battle - Page 29




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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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