Chi Wai - Page 13

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          Office not to accept her OIC.  See id. at 175-176.  As we pointed           
          out there, “The unfortunate consequences of the AMT in various              
          circumstances have been litigated since shortly after the                   
          adoption of the AMT.  In many different contexts, literal                   
          application of the AMT has led to a perceived hardship, but                 
          challenges based on equity have been uniformly rejected.”  Id. at           
          176 (and cases cited therein).                                              
               Petitioner asserts “economic hardship” as a justification              
          for compromise and that it should be expansively construed by               
          respondent to constitute an available ground for accepting the              
          OIC.  Pursuant to section 301.7122-1(c), Proced. & Admin. Regs.,            
          economic hardship constitutes a basis for compromise, although              
          the compromise is classified within the ETA rubric.  ETA is                 
          bifurcated into subcategories of enumerated justifications for              
          compromise in section 301.7122-1(c), Proced. & Admin. Regs.--the            
          aforementioned public policy and equity, and economic hardship.             
          The following three scenarios are depicted in section 301.7122-             
          1(c), Proced. & Admin. Regs., as supporting (but not conclusive             
          of) a determination of economic hardship:  A taxpayer suffering             
          from a long-term illness, medical condition, or disability, which           
          is expected to exhaust the taxpayer’s financial resources; total            
          depletion of a taxpayer’s income resulting as a result of the               
          provision of dependent care; and an inability of a taxpayer to              
          exploit existing asset wealth in order to finance both basic                






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