Dennis and Nancy Flynn - Page 4

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               In a letter dated June 10, 1996, petitioner said that                  
          petitioners had one mortgage with a balance due of $259,492.47              
          and monthly payments of $2,084.36 for principal and interest.               
          Petitioner wrote that their certified public accountant and                 
          attorney had told them that foreclosure on petitioners’ home                
          would generate $61,548 of additional income tax in the year of              
          the foreclosure.  Petitioner said that their son had been                   
          diagnosed with attention deficit disorder and Tourette’s                    
          syndrome, and that the benefits of the private high school                  
          attended by their son far outweighed the $350 per month tuition             
          cost.                                                                       
               Petitioner attached to his June 10, 1996, letter, a letter             
          from a realtor stating that it was highly likely that the                   
          proceeds from the sale of the home would be less than the balance           
          due on the mortgage.  Petitioner provided documents showing that            
          utilities had cost $230.32 per month for the previous 3 months.             
          Petitioner attached a letter from a dean of the College of the              
          Pacific stating that petitioner was required to pay $500 per                
          month for unreimbursed employee expenses.  Petitioner also                  
          attached documents showing the balances of petitioners’                     
          retirement funds.  Petitioner said that petitioners could not               
          withdraw those funds.                                                       
               On September 27, 1996, petitioners filed with respondent an            
          Application for Taxpayer Assistance Order (Taxpayer’s Application           






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