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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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