Barry and Sherry Blondheim - Page 16

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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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