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evaluating petitioners’ particular circumstances. We find no
abuse of discretion in these adjustments.
Fourth, petitioners argue that Cochran did not adequately
take into account the economic hardship they claim they will
suffer by having to pay more than $35,000 as to their tax
liability. We disagree. 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
illustrative examples. One of the examples involves a taxpayer
who provides full-time 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 with 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 “describe more dire circumstances”. Speltz
v. Commissioner, 454 F.3d at 786.
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