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fair and equitable manner; and (2) compromise will not undermine
compliance by taxpayers with the tax laws. Sec. 301.7122-
1(b)(3), Proced. & Admin. Regs. Economic hardship is defined as
an inability to meet reasonable basic living expenses. Sec.
301.6343-1(b)(4)(i), Proced. & Admin. Regs.
Turning to the case at bar, the Court certainly sympathizes
with the personal and medical difficulties endured by petitioner
in recent years. However, the record lacks evidence that would
establish an abuse of discretion on the part of respondent in
evaluating petitioner’s circumstances. The only Form 433-A in
evidence submitted by petitioner, despite repeated invitations to
provide updated documentation, does not, when analyzed in
accordance with the IRM, show that an installment agreement of
$700 would be unreasonable. Nor does it establish an inability
to meet basic living expenses.
The only other financial information offered by petitioner;
i.e., the figures set forth in her December 2, 2004, response to
the motion for summary judgment and testified to at trial, is
problematic on several fronts. First and foremost, the amounts
are completely unsubstantiated. There would also appear to be
rounding and estimation, the extent of which is unclear. The
reference to an expense for chemotherapy, for instance, is broad,
generalized, and affords no meaningful way to arrive at a monthly
outlay. Furthermore, the $75 monthly payment suggested by
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