- 13 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011