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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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