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signing the return or requesting relief. Rev. Proc. 2003-61,
sec. 4.03(2), further provides that no single factor will be
determinative, but that all relevant factors will be considered.
We will now consider petitioner’s request in the light of these
relief factors.
In this case, petitioner divorced Ms. Payton in 2000;
therefore, he satisfies the first factor. With respect
to the second factor, petitioner must show that he would be
unable to pay basic reasonable living expenses if relief were not
granted. See Monsour v. Commissioner, T.C. Memo. 2004-190.
Being unable to pay basic reasonable living expenses would amount
to economic hardship. Sec. 301.6343-1(b)(4)(i), Proced. & Admin.
Regs. Petitioner has alleged that denial of his request for
relief would result in economic hardship for his family “for the
next 140 years.” He is gainfully employed as a schoolteacher and
has no dependents. The Court fails to see, and petitioner has
neither raised as an issue nor established, that he would suffer
economic hardship if his request for relief from joint liability
were denied.
As to the third factor, as discussed earlier, petitioner had
actual knowledge of all of the claimed Schedules C and E business
and rental expenses, rental income, and itemized deductions when
he completed the 2001 income tax return. Rev. Proc. 2003-61,
sec. 4.03, specifically states that actual knowledge by the
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