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sec. 301.6343-1(b)(4)(i), Proced. & Admin. Regs. Therefore, we
conclude that petitioner does not qualify for relief under Rev.
Proc. 2003-61, sec. 4.02, 2003-2 C.B. at 298.
Where the requesting spouse satisfies the seven threshold
conditions set forth in Rev. Proc. 2003-61, sec. 4.01, but does
not qualify for relief under Rev. Proc. 2003-61, sec. 4.02, she
may still be granted relief if, upon taking into account all the
facts and circumstances, it would be inequitable to hold the
requesting spouse liable for all or part of the unpaid
deficiency. Rev. Proc. 2003-61, sec. 4.03, 2003-2 C.B. at 298,
lists six factors to be considered in determining whether to
grant equitable relief. Again, when considering petitioner’s
appeal, although respondent maintained that petitioner did not
meet the seventh threshold requirement, he would nonetheless
consider other factors. Accordingly, we now address petitioner’s
request in the light of those factors.
In this case, petitioner and Mr. Poe divorced in 2003;
therefore, she satisfies the first factor. With respect
to the second factor, petitioner must show that she 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 not alleged that denial of her request for
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