- 24 - bearing striking similarity to the exhibits not admitted at trial (with the income and expense listings now bearing two columns, one labeled November 14, 2005, and the other labeled February 2005). However, the tables incorporate noticeably more detail and precision than can reasonably be gleaned from petitioner’s often generalized approximations from the stand. It is the status of the record as just described that precipitated the Court’s comment that the outcome of the case is unaffected regardless of any proffered information considered in augmentation of the administrative record. The complete dearth of any documentation to corroborate or substantiate the figures renders petitioner’s various estimates unpersuasive in any event. Moreover, the Court would observe that only the computations purporting to detail income and expenses as of February 2005 show an excess of expenses over income, and it is decidedly questionable whether all of those expenses shown are properly taken into account for purposes of section 301.6343-1(b)(4), Proced. & Admin. Regs. (for example, charitable contributions and payments on various liabilities). The Court is therefore constrained to conclude that petitioner has failed to establish economic hardship within the meaning of Rev. Proc. 2003-61, sec. 4.02, 2003-2 C.B. at 298. Accordingly, on account of failure to satisfy two of the three elements enumerated as delineating those circumstances in whichPage: Previous 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 NextLast modified: November 10, 2007