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theft rendered petitioner unable to pay the tax reported on the
2001 return at the time of filing. Further, petitioner has not
shown to the Court’s satisfaction that he would experience
economic hardship if he were forced to pay the tax liabilities
for the years at issue. A taxpayer might experience economic
hardship if he or she were unable to pay basic reasonable living
expenses. Sec. 301.6343-1(b)(4)(i), Proced. & Admin. Regs. Even
taking into account the monthly payments being made on the
installment agreements for 2000 and 2001, petitioner acknowledged
that he managed to pay his basic living expenses.
Rev. Proc. 2000-15, sec. 4.03, 2000-1 C.B. at 448, provides
factors to be evaluated for requests for relief under section
6015 for requesting spouses who filed a joint return and do not
qualify for relief under Rev. Proc. 2000-15, sec. 4.02. Rev.
Proc. 2000-15, sec. 4.03(1), offers a partial list of positive
factors to be considered, including: (1) Marital status; (2)
economic hardship; (3) abuse; (4) no knowledge or reason to know
that the reported liability would not be paid; (5) whether the
nonrequesting spouse had a legal obligation to pay the liability;
and (6) whether the liability for which relief is sought is
solely attributable to the nonrequesting spouse. Negative
factors weighing against relief in Rev. Proc. 2000-15, sec.
4.03(2), 2000-1 C.B. at 449, include: (1) The unpaid liability
is attributable to the requesting spouse; (2) the requesting
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