Kathryn Ann Picchiottino - Page 13

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          under this standard where arbitrary, capricious, or without sound           
          basis in fact or law.  Woodral v. Commissioner, 112 T.C. 19, 23             
          (1999).                                                                     
               Here, the record reflects no abuse of discretion by                    
          respondent in declining to alter the proposed collection activity           
          on account of petitioner’s unsupported assertions of financial              
          difficulties.  To enable the Commissioner to evaluate a                     
          taxpayer’s qualification for collection alternatives or other               
          relief in the face of allegations of economic hardship, the                 
          taxpayer must submit complete and current financial data.                   
               Petitioner, however, never supplied a current Form 433-A,              
          Collection Information Statement for Wage Earners and Self-                 
          Employed Individuals, or other financial information to                     
          respondent, despite an express request and explanation of the               
          reason therefor from respondent.  The notice of determination               
          indicates that earlier financial information, furnished by                  
          petitioner’s former husband, had generated the temporary “not               
          collectible” designation made by “Compliance”.  These materials             
          were not signed by petitioner and did not report her income and             
          assets.  Petitioner did not submit current financial information            
          when asked to do so.  She also failed to appear for the scheduled           
          hearing and thus lost that opportunity to otherwise corroborate             
          her claims.                                                                 








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