Kenneth Hawkins - Page 14

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          caring for dependents, and (3) the taxpayer may be unable to                
          borrow against the equity in assets so that enforced collection             
          is unlikely.  Id.  Petitioner alleges that the first and third              
          factors are relevant to his situation.                                      
               Petitioner alleges that his wife’s permanent disability                
          makes the first factor relevant.  The only evidence petitioner              
          offered concerning his wife’s disability was:  (1) His statement            
          in the second offer that his wife was unemployable, was on Social           
          Security disability, and earned no income; and (2) his own                  
          general testimony that his wife became disabled in 1999.  When he           
          made his offer petitioner did not state the nature of her                   
          disability, present any evidence of its financial effect, or even           
          allege that it caused economic hardship.  The only monthly                  
          expense submitted in the second offer that could have related to            
          his wife’s disability was health insurance of $340, representing            
          only 10 percent of the claimed expenses.  The lack of any                   
          evidence or specificity to support petitioner’s allegation left             
          respondent without an adequate basis for making any findings                
          concerning the financial impact of the alleged disability.  There           
          is no indication that the revenue officer summarily refused to              
          consider any changed circumstances of petitioner.  Rather,                  
          petitioner did not provide sufficient proof of the nature and               
          extent of his alleged hardship.                                             
               Furthermore, when economic hardship is a factor in a doubt-            






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