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longterm illness. A second example involves a taxpayer who would
lack adequate means to pay his basic living expenses were his
only asset to be liquidated. A third example involves a disabled
taxpayer with a fixed income and a modest home specially equipped
to accommodate his disability, and who is unable to borrow
against his home because of his disability. See sec.
301.7122-1(c)(3)(iii), Examples (1), (2), and (3), Proced. &
Admin. Regs. None of these examples bears any resemblance to
this case but instead “describe more dire circumstances”. Speltz
v. Commissioner, F.3d at .
Nor have petitioners articulated with any specificity the
purported economic hardship they will suffer if they are not
allowed to compromise their liability for $32,000. While
petitioners claim generally that the sale of their residence
would create an economic hardship in that they would be unable to
afford paying either rent or a mortgage, this claim is vague,
speculative, undocumented, and unavailing.11 Nor are we
persuaded by petitioners’ suggestion that their health is an
“economic hardship” by virtue of section 301.7122-1(c)(3)(i)(A),
Proced. & Admin. Regs. In this regard, petitioners have given us
11 We note that our opinion here does not necessarily mean
that respondent may in fact levy on petitioners’ residence in
payment of their tax debt. Pursuant to sec. 6334(a)(13)(B) and
(e), a taxpayer’s principal residence is exempt from levy absent
the written approval of a U.S. District Court Judge or
Magistrate. See also sec. 301.6334-1(d), Proced. & Admin. Regs.
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