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only 48 months of future income should be considered.
Petitioners made a cash offer, but Ms. Cochran used 81 months of
future income. At trial, Ms. Cochran acknowledged that she
should have used only 48 months of future income. Ms. Cochran
recomputed petitioners’ reasonable collection potential using 48
months and determined that it was $351,531, instead of $380,076,
as reflected in the notice of determination. Ms. Cochran
testified that the change would not have had an effect on her
final determination because, using either calculation,
petitioners’ reasonable collection potential was greater than
their offer amount ($25,000). We find that Ms. Cochran’s error
did not amount to an abuse of discretion because, even when the
error is corrected, petitioners’ reasonable collection potential
of $351,531 far exceeds their offer amount of $25,000.
With regard to age, health, and retirement status,
petitioners’ argument is not supported by the record. In their
letter describing their offer amount, petitioners represented
that Mrs. Andrews was retired and Mr. Andrews would retire when
he reached 65 years old. Petitioners also indicated that they
suffered from various medical conditions and that Mrs. Andrews
was taking several medications. On their Form 433-A, petitioners
reported monthly medical expenses of $533.
Ms. Cochran accepted petitioners’ monthly medical expenses
without change. Ms. Cochran also accepted petitioners’
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