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substantiation of these costs to Cochran. Because petitioners
did not submit any documentation of future medical expenses, we
find that Cochran did not abuse her discretion in not allowing
future medical costs that are entirely speculative. See Fargo v.
Commissioner, 447 F.3d at 710 (it is not an abuse of discretion
for Appeals to disregard claimed medical expenses that are
speculative or not related to the taxpayer); see also Clayton v.
Commissioner, supra; Barnes v. Commissioner, supra.
Fourth, petitioners argue that Cochran did not adequately
take into account the economic hardship they claim they will
suffer by having to pay more than $83,213 of their tax liability.
We disagree. Section 301.6343-1(b)(4)(i), Proced. & Admin.
Regs., states that economic hardship occurs when a taxpayer is
“unable to pay his or her reasonable basic living expenses.”
Section 301.7122-1(c)(3), Proced. & Admin. Regs., sets forth
factors to consider in evaluating whether collection of a tax
liability would cause economic hardship, as well as some
illustrative examples. One of the examples involves a taxpayer
who provides fulltime care to a dependent child with a serious
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
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