- 13 - certainly reduced petitioner’s expendable income in November and December of 2000, it does not establish that payment of the outstanding tax liability would prevent petitioner from paying reasonable basic living expenses. Petitioner has presented no evidence, either to respondent or to the Court, that she would suffer economic hardship if denied relief. Common sense suggests that payment of the outstanding tax liability would put petitioner in a less-than-desirable financial situation. However, based on petitioner’s complete lack of proof, we have no choice but to conclude petitioner would not suffer economic hardship if she were denied relief. This factor weighs against relief. 6. Knowledge or Reason To Know In determining whether a taxpayer qualifies for equitable relief under section 6015(f), the Commissioner considers whether the requesting spouse knew or had reason to know that the reported liability would be unpaid at the time the return was signed. Rev. Proc. 2000-15, sec. 4.03(2)(b), 2000-1 C.B. at 449. Respondent determined that petitioner knew or had reason to know that the reported liability would be unpaid when the 1998 and 1999 returns were filed. Petitioner argues that she was unaware of the tax problems surrounding Mr. Crouch’s businessPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007