Joseph G. Dostal - Page 22

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             that amount is more than enough to finance the payment of                
             petitioner’s unpaid taxes for 2000 and 2001.                             
                  Petitioner’s contention that he faced economic                      
             hardship from collection of his full tax liability for                   
             taxable years 2000 and 2001 appears to be based upon the                 
             assertion that he planned to retire from his stock                       
             brokerage business.  In that event, as we understand                     
             petitioner’s contention, he would have no business income,               
             and collection of his full tax liability for 2000 and 2001               
             would deprive him of those assets and a means of support                 
             for himself and his family.  We note that petitioner’s                   
             retirement is not required for health reasons or any                     
             external cause.  Petitioner’s complaint boils down to the                
             fact that if collection of his full tax liability for                    
             taxable years 2000 and 2001 is required, then petitioner                 
             will have to delay his retirement plans.  We agree with                  
             the Appeals officer that petitioner has not shown that                   
             requiring full payment would cause economic hardship.                    
                  To reflect the foregoing,                                           

                                                Decision will be                      
                                           entered for respondent.                    










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