Gary W. McDonough - Page 14

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         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 all “describe                
         more dire circumstances”.  Speltz v. Commissioner, 454 F.3d 782,             
         786 (8th Cir. 2006), affg. 124 T.C. 165 (2005); see also Barnes              
         v. Commissioner, T.C. Memo. 2006-150.  Nevertheless, we will                 
         address petitioner’s arguments.                                              
                   1.   Discussion of Special Circumstances in the Notice             
                        of Determination                                              
              Petitioner argues that Ms. Cochran failed “to follow proper             
         procedure by [not] discussing Petitioner’s special circumstances,            
         what equity was considered in relation to his special                        
         circumstances, and how the special circumstances affected her                
         determination of his ability to pay.”  Petitioner infers that,               
         because the notice of determination did not discuss the special              
         circumstances in detail, Ms. Cochran failed to adequately take               
         petitioner’s circumstances into consideration.                               
             This Court does not believe that Appeals must specifically              
         list in the notice of determination every single fact it                     
         considers in arriving at a determination.  See Barnes v.                     
         Commissioner, supra.  This is especially true in a case such as              
         this, where petitioner provided Ms. Cochran with multiple letters            
         and hundreds of pages of exhibits.  Ms. Cochran considered all of            

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