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Petitioners’ demonstrated special circumstances or that they
would experience a hardship if required to make a full-payment.”
In support of this assertion, petitioners argue: (1) Ms. Cochran
failed to discuss petitioners’ special circumstances in the
notice of determination; (2) Ms. Cochran erroneously determined
petitioners’ future income and failed to take into account their
future expenses; and (3) Ms. Cochran improperly valued
petitioners’ house.
Section 301.6343-1(b)(4)(i), Proced. & Admin. Regs., states
that economic hardship occurs when a taxpayer is “unable to pay
his or her reasonable basic living expenses.” Section 301.7122-
1(c)(3), Proced. & Admin. Regs., sets forth factors to consider
in evaluating whether collection of a tax liability would cause
economic hardship, as well as some examples. One of the examples
involves a taxpayer who provides fulltime care to a dependent
child with a serious long-term illness. A second example
involves a taxpayer who would lack adequate means to pay his
basic living expenses were his only asset to be liquidated. A
third example involves a disabled taxpayer who has a fixed income
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
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