James Weldon Aaron - Page 11

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          circumstances exist such that collection of the full liability              
          would undermine public confidence that the tax laws are being               
          fairly and equitably administered.  Speltz v. Commissioner, 124             
          T.C. 165, 172-174 (2005); sec. 301.7122-1(b)(3), Proced. & Admin.           
          Regs.                                                                       
               1.  Economic Hardship                                                  
               Factors supporting (but not conclusive of) a determination             
          that collection would cause economic hardship include, but are              
          not limited to:                                                             
                    (A) Taxpayer is incapable of earning a living                     
               because of a long term illness, medical condition, or                  
               disability, and it is reasonably foreseeable that                      
               taxpayer’s financial resources will be exhausted                       
               providing for care and support during the course of the                
               condition;                                                             
                    (B) Although taxpayer has certain monthly income,                 
               that income is exhausted each month in providing for                   
               the care of dependents with no other means of support;                 
               and                                                                    
                    (C) Although taxpayer has certain assets, the                     
               taxpayer is unable to borrow against the equity in                     
               those assets and liquidation of those assets to pay                    
               outstanding tax liabilities would render the taxpayer                  
               unable to meet basic living expenses.                                  
          Sec. 301.7122-1(c)(3)(i), Proced. & Admin. Regs.                            
               Petitioner does not contend that he has a long-term illness,           
          medical condition, or disability.  Nor does he claim that                   
          borrowing against the equity in his real property interests would           
          render him unable to meet basic living expenses.  Although                  
          petitioner contributes to the support of his family, he has                 






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