William H. and Jo Anne Lindley - Page 18

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          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...)           





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