- 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...)
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