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allowances”, referred to in section 7122(c)(2), and failed
to determine, based upon the facts and circumstances of
this case, whether it was appropriate to use those
schedules.
For his last reason, petitioner argues that “the
financial information clearly showed that the IRS’
settlement demands would be an undue hardship on the
taxpayer and his family, and basically force them into the
streets.” In effect, petitioner is arguing that collection
of the full liability for tax years 2000 and 2001 would
cause petitioner and his family economic hardship within
the meaning of section 301.6343-1, Proced. & Admin. Regs.
Thus, it appears that petitioner is relying on section
301.7122-1(b)(3)(i), Proced. & Admin. Regs., to support his
contention that respondent should have accepted his offer-
in-compromise. Petitioner has identified no “compelling
public policy or equity considerations”, applicable to his
tax liability for taxable years 2000 and 2001, that would
provide a basis to apply section 301.7122-1(b)(3)(ii),
Proced. & Admin. Regs.
We disagree with each of petitioner’s points and, for
the reasons set out below, we find that the determination
to proceed with collection of petitioner’s tax for 2000
and 2001 was not an abuse of respondent’s discretion.
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