Teresa G. Butner - Page 31




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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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