Sandrus L. Collier - Page 27

                                       - 27 -                                         
               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                

Page:  Previous  17  18  19  20  21  22  23  24  25  26  27  28  29  30  31  32  33  34  35  36  Next

Last modified: May 25, 2011