Fay B. Edwards - Page 9

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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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