The petitioner had an outstanding tax liability at the time he received proceeds from the sale of his home and business. However, the petitioner spent the funds without paying the tax liability. The court upheld the position of the IRS that the sale proceeds constituted "dissipated assets" that should be included in the petitioner's reasonable collection potential based on all of the facts and circumstances. The petitioner failed to carry the burden of proof that the proceeds were spent on reasonable living expenses. The court computed the petitioner's reasonable collection potential. Porro v. Comr., T.C. Memo. 2014-81.