Estate of Carol Andrews, Deceased, Robert Andrews, Special Administrator, and Robert Andrews - Page 16

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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 they “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, supra.  Nevertheless, we address petitioners’              
               1.   Discussion of Special Circumstances in the Notice of              
               Petitioners argue that Ms. Cochran failed “to follow proper            
          procedure by discussing Petitioners’ special circumstances, what            
          equity was considered in relation to their special circumstances,           
          and how the special circumstances affected her determination of             
          their ability to pay.”  Petitioners infer that, because the                 
          special circumstances were not discussed in detail in the notice            
          of determination, Ms. Cochran failed to adequately take their               
          circumstances into consideration.                                           
              We do not believe that Appeals must specifically list in the           
          notice of determination every single fact that it considered in             
          arriving at the determination.  See Barnes v. Commissioner,                 
          supra.  This is especially true in a case such as this, where               
          petitioners provided Ms. Cochran with multiple letters and                  
          hundreds of pages of exhibits.  As discussed below, Ms. Cochran             

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