- 12 -
Secured and unsecured debts, i.e., credit card debt, are examples
of conditional expenses. See Lemann v. Commissioner, T.C. Memo.
2006-37 n.12; 2 Administration, Internal Revenue Manual (CCH),
sec. 5.15.1.10, at 17662, 17664.
Respondent’s “Appeals Case Memo” states only: “Economic
Hardship. Not in favor - RS has not demonstrated an economic
hardship.”
Petitioner claimed on her Form 433-A, Collection Information
Statement for Wage Earners and Self-Employed Individuals,
expenditures that were not properly substantiated or were in
excess of the national or local standard. Accordingly, the Court
will use the following amounts in its analysis of petitioner’s
claim of economic hardship:
Expenditure Amount Allowed
Food, clothing, misc. 1$1,331.00
Housing and utilities 12,239.00
Transportation 11,344.00
Other “secured debt” 22,095.94
Other “unsecured debt” -0-
1 Based on the national or local standard.
2 Taxes, insurance, and first and second
mortgages on the rental property.
Petitioner’s Form 433-A indicates that petitioner and her
second husband’s total monthly income is $6,050. On her Form
433-A, petitioner claimed that her rental property’s current
value is $325,000 with encumbrances totaling $369,000.
Petitioner claimed $410,000 as the current value of her principal
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Last modified: March 27, 2008