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The Appeals officer considered and adjusted the financial
information submitted by petitioners and concluded that
petitioners could pay the balance of their tax liability by use
of an installment agreement. See generally Orum v. Commissioner,
123 T.C. 1, 13-14 (2004). Neither the information provided to
the Appeals officer nor that provided to the Court in this case
shows that it was not reasonable for the Appeals officer to
conclude that petitioners have the ability to pay over time the
balance of the tax liability. Petitioners contend that they
should not be required to pay the full amount. We are not
unsympathetic to the burdens and lifestyle changes that
petitioners have and may suffer as a result of their tax
liability. Petitioners have not contended or shown, however, any
invalidity in the Appeals officer’s determination of their basic
living expenses as that term is used in section 7122.
Petitioners seek to have the Court redefine “hardship”, “special
circumstances”, and “efficient tax administration” in a manner
different from that set forth in the regulations and in the
Internal Revenue Manual.
There is a dispute between the parties with respect to the
individual adjustments used by the Appeals officer in determining
that petitioners could pay the remaining tax liability under an
installment plan. Respondent has suggested some revised
computations and a remand for further consideration of
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