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In support of this assertion, petitioners argue: (1) Ms. Cochran
failed to discuss petitioners’ special circumstances in the
notice of determination; and (2) Ms. Cochran erroneously
determined petitioners’ future income, improperly valued
petitioners’ assets, and failed to take into account their future
expenses.
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
more dire circumstances”. Speltz v. Commissioner, 454 F.3d 782,
786 (8th Cir. 2006), affg. 124 T.C. 165 (2005); see also Barnes
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