Cheryl Kunsman - Page 14

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               1.  Marital status:  Petitioner is divorced from her former            
          spouse.  This factor weighs in favor of relief.                             
               2.  Economic hardship:  Respondent’s tax examiner considered           
          petitioner’s submission in support of her request for relief from           
          joint and several liability, noted that her income and expenses             
          needed verification, and determined that refusal to grant relief            
          would not cause petitioner to suffer economic hardship.                     
          Respondent’s Appeals officer also determined from respondent’s              
          record and research that petitioner would not suffer an economic            
          hardship as a result of remaining liable for the $1,582.58                  
          balance due for 1999.                                                       
               Respondent determines economic hardship by evaluating                  
          whether or not petitioner is able to pay her reasonable basic               
          living expenses.  Rev. Proc. 2003-61, sec. 4.02(c), 2003-2 C.B.             
          at 298 (referring to sec. 301.6343-1(b)(4), Proced. & Admin.                
          Regs.).  It is petitioner’s burden to show that her living                  
          expenses qualify, that those expenses are reasonable, and that              
          she is unable to pay those expenses.  Monsour v. Commissioner,              
          T.C. Memo. 2004-190.                                                        
               Petitioner claimed that continuing liability for the 1999              
          deficiency would cause her economic hardship and asserted that              
          her income was $1,000 per month while her expenses were $1,520              
          per month.  She offered no evidence of either income or expenses            
          and no proof that the 1999 tax liability would render her unable            

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