- 18 - run those risks, thus undermining rather than enhancing compliance with the tax laws. See Barnes v. Commissioner, supra. On brief, petitioners advance numerous arguments relating to doubt as to collectibility with special circumstances and effective tax administration. Because we find that Mr. Owens did not abuse his discretion in concluding that petitioners had abandoned those arguments, we need not address those arguments. B. Doubt as to Collectibility Petitioners assert that Mr. Owens erroneously determined their reasonable collection potential by: (1) Reducing their allowable housing and utilities expense from $2,421 to $1,235 and disallowing their second mortgage expense; (2) reducing their allowable food, clothing, misc. expense from $2,450 to $868; (3) disallowing their other expenses; (4) failing to reduce the value of the annuity by its liquidation costs; and (5) including $155,500 in “other assets” to reflect the dissipation of assets.12 Although Mr. Owens made some errors in calculating 12 Petitioners also argue that Mr. Owens erred by not allowing as a monthly expense $600 given to their daughter to pay for college-related expenses. This “expense” was not listed on petitioners’ Form 433-A or other letters, nor did they indicate that the $600 was part of another expense, such as food, clothing, misc. or other expenses. On brief, petitioners do not show when, if at all, they brought this expense to Mr. Owens’s attention. Because this expense was not before Mr. Owens, it is not relevant to our determination of whether Mr. Owens abused his discretion. (continued...)Page: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Next
Last modified: May 25, 2011