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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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