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bility will cause a taxpayer to be unable to pay such taxpayer’s
reasonable basic living expenses.
The parties stipulated that petitioner has not verified that
she would suffer an economic hardship if relief from joint and
several liability for each of the taxable years 1994, 1995, 1998,
and 1999 were not granted. Furthermore, it appears from the
record that petitioner has assets such that she would not experi-
ence economic hardship if required to pay some or all of the
liabilities at issue. Petitioner has not entered into evidence
any documentary or testimonial evidence to contradict respon-
dent’s contention that she will not suffer economic hardship if
relief were denied. We find that petitioner will not suffer
economic hardship if relief under section 6015(f) were not
granted. This factor weighs against granting relief.
14(...continued)
payments, and expenses necessary to the taxpayer's
production of income (such as dues for a trade union or
professional organization, or child care payments which
allow the taxpayer to be gainfully employed);
(C) The cost of living in the geographic area in
which the taxpayer resides;
(D) The amount of property exempt from levy which
is available to pay the taxpayer's expenses;
(E) Any extraordinary circumstances such as special
education expenses, a medical catastrophe, or natural
disaster; and
(F) Any other factor that the taxpayer claims
bears on economic hardship and brings to the attention
of the director.
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Last modified: November 10, 2007