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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
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 will address
petitioner’s arguments.
1. Discussion of Special Circumstances in the Notice of
Determination
Petitioner argues that Ms. Cochran failed “to follow proper
procedure by [not] discussing Petitioner’s special circumstances,
what equity was considered in relation to his special
circumstances, and how the special circumstances affected her
determination of his ability to pay.” Petitioner infers that,
because the special circumstances were not discussed in detail in
the notice of determination, Ms. Cochran failed to adequately
take petitioner’s 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
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