- 6 - round-the-clock nursing care. They claim that such care is so expensive (almost $90,000/year, by their estimate) that it would cause them to wholly consume their liquid assets in 10 years. They argue that respondent should have accepted their offer as a viable alternative to a levy because of this foreseeable economic hardship. As we already noted, we look to respondent’s determination for anything that runs counter to established law or suggests the lack of a “sound basis in fact or law.” In that light, we decline to second-guess his determination that petitioners’ resources are sufficient to warrant collection of the entire outstanding liability. The record compiled by respondent indicates that petitioners possess substantial wealth--over a million dollars in total assets (if equity in real estate is counted) and a large income even in their retirement. While petitioners certainly present a legitimate view of their possible future needs, we do not find that the record shows respondent to have abused his discretion in concluding that petitioners can pay their debt without suffering substantial economic hardship. B. Exceptional Circumstances Petitioners also renew here the arguments in favor of a finding of “exceptional circumstances” that they made to respondent. First, they contend the IRS had no justification for its extraordinary delay in assessing their unpaid tax liabilityPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011