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Fargo v. Commissioner, 447 F.3d at 710 (it is not an abuse of
discretion to disregard claimed medical expenses that are
speculative or not related to the taxpayer).
Third, petitioners argue that Cochran did not adequately
take into account the economic hardship they claim they will
suffer by having to pay more than $100,000 as to 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
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, 454 F.3d at 786.
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