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Petitioner and Mr. Butner were married in 1984 and remained
married as of the time of trial. In addition, petitioner and Mr.
Butner resided together during the 12 months preceding peti-
tioner's filing Forms 8857 with respect to the respective taxable
years at issue, in which she requested relief under section 6015
for those years.
Economic Hardship
Respondent contends that petitioner will not suffer economic
hardship if relief were denied. In determining whether a re-
questing spouse will suffer economic hardship, section 4.02(1)(c)
of Revenue Procedure 2000-15 requires reliance on rules similar
to those provided in section 301.6343-1(b)(4), Proced. & Admin.
Regs. Under section 301.6343-1(b)(4)(ii), Proced. & Admin.
Regs.,14 economic hardship exists if collection of the tax lia-
14Sec. 301.6343-1(b)(4)(ii), Proced. & Admin. Regs.,
provides in pertinent part:
(ii) Information from taxpayer.--In determining a
reasonable amount for basic living expenses the
director will consider any information provided by the
taxpayer including--
(A) The taxpayer's age, employment status and
history, ability to earn, number of dependents, and
status as a dependent of someone else;
(B) The amount reasonably necessary for food,
clothing, housing (including utilities, home-owner
insurance, home-owner dues, and the like), medical
expenses (including health insurance), transportation,
current tax payments (including federal, state, and
local), alimony, child support, or other court-ordered
(continued...)
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