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tor will consider any information provided by the
taxpayer including–-
(A) The taxpayer’s age, employment status and
history, ability to earn, number of dependents, and
status as a dependent of someone else;
(B) The amount reasonably necessary for food,
clothing, housing (including utilities, home-owner
insurance, home-owner dues, and the like), medical
expenses (including health insurance), transportation,
current tax payments (including federal, state, and
local), alimony, child support, or other court-ordered
payments, and expenses necessary to the taxpayer’s
production of income (such as dues for a trade union or
professional organization, or child care payments which
allow the taxpayer to be gainfully employed);
(C) The cost of living in the geographic area
in which the taxpayer resides;
(D) The amount of property exempt from levy
which is available to pay the taxpayer’s expenses;
(E) Any extraordinary circumstances such as
special education expenses, a medical catastrophe, or
natural disaster; and
(F) Any other factor that the taxpayer claims
bears on economic hardship and brings to the attention
of the director. [Sec. 301.6343-1(b)(4)(ii), Proced. &
Admin. Regs.]
Assuming arguendo that the expenses claimed by Ms. Collier
(i.e., expenses relating to her adult son’s college education,
her own postgraduate work, and the care of her mother) qualify as
basic living expenses within the meaning of section 301.6343-
1(b)(4), Proced. & Admin. Regs.,20 Ms. Collier presented no
20We are persuaded on the record before us that the expenses
for the care by Ms. Collier of her mother qualify as basic living
expenses within the meaning of that regulation. However, as
(continued...)
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