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officer assumed petitioner’s annual gross wages were
approximately $30,000. Regardless of whether the $30,000 gross
wages estimation or the $51,000 actual gross wages is used in the
computation to determine economic hardship, petitioner’s actual
medical expenses presented at trial are not substantial enough
for us to conclude that she would be unable to pay her basic
living expenses if relief were not granted.
Respondent argues that we should limit our review of the
denial of section 6015(f) relief to the record available to the
Appeals officer during respondent’s administrative review and
refuse to consider petitioner’s medical expenses because the
substantiating log of expenses is not part of the administrative
record. In view of our conclusion that the evidence is
insufficient to show economic hardship, we need not address
respondent’s argument.
Rev. Proc. 2003-61, sec. 4.03, 2003-2 C.B. at 298, provides
an alternative test for equitable relief if a taxpayer does not
meet the requirements of Rev. Proc. 2003-61, sec. 4.02. Rev.
Proc. 2003-61, sec. 4.03, lists several relevant factors that the
Commissioner considers and weighs in making a determination about
whether section 6015(f) relief should be granted. Those factors
include:
(i) Whether the requesting spouse is separated or divorced
from the nonrequesting spouse;
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