- 18 - broadly as petitioners. Fargo does not support their claim that Appeals was automatically required to accept petitioners’ bargain-basement offer of $11,552. It cannot be gainsaid that a significant motivation of their investment in the Hoyt tax shelters was to realize tax savings. Petitioners also argue that their offer was required to be accepted because they adequately demonstrated that they will suffer economic hardship if required to pay their assessed tax liability in full. To this end, petitioners state, Driver ignored both their medical issues and their age and retirement status in making her determination, and it is “reasonably foreseeable” that they will need all of their home equity and retirement assets to compensate for this shortfall and to use for their care and support in the future. By petitioners’ count, their monthly income is exceeded by their monthly expenses, creating a deficit of $819 (i.e., monthly income of $3,223 less monthly living expenses of $4,042), and Driver’s analysis requires that they liquidate all of their retirement accounts and home equity in order to pay their tax liability. We disagree with petitioners that they have demonstrated that requiring them to pay more than $11,552 towards their assessed tax liability will result in an economic hardship.9 The 9 Even if they had shown economic hardship, a compromise on the basis of effective tax administration will not be made if it (continued...)Page: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 NextLast modified: November 10, 2007