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sustain the underlying tax liabilities for 1996, 1997, 1998,
2000, and 2001.
Petitioner submitted her financial information only a few
weeks prior to trial.2 Petitioner’s total tax liability,
including penalties and interest accrued as of April 2004, is
approximately $15,734.10. In her financial information she
disclosed assets significantly greater than the total tax
liability, including a bank account in excess of $100,000 and a
home that she owns free of encumbrances. Her financial
information indicates that petitioner is able to pay her tax
liability in full.
We are not persuaded by petitioner’s arguments that she
needs money to make expensive repairs to her home or that she
anticipates having significant medical and long-term health care
costs in the future. We are sympathetic to petitioner because of
her present and anticipated future problems. She has explained
that her house is 100 years old, needs a new roof, and does not
even have central heating. But she does not dispute that the
house has some value, and there is no evidence as to the amount
of the value. Petitioner was almost 82 years of age at the time
of the hearing, and we have no reason to doubt that like many
2 It appears that settlement negotiations regarding a
collection alternative between the parties failed. Petitioner
stated: “I notice here I have in my notes that unfortunately the
information [that I provided] confirmed that * * * I am not
eligible to compromise the amount of taxes that I owe.”
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