Bea-Jaye Ware - Page 13




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          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 business               










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