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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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Last modified: May 25, 2011