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Hubbart had a history of ulcerative colitis, and has to have a
colonoscopy each year, for which she has to pay $1,000; and (3)
Mr. Hubbart suffered from heart problems, had an angioplasty and
an angiogram during 2004, required 35 sessions of a treatment
called External Counterpulsion System beginning April 19 and
ending June 4, 2004, and would likely require heart bypass
surgery in the future. The retirement analysis outlined the
likelihood of increased housing and medical costs as petitioners
age.
In the remaining three letters, petitioners alleged that
they were victims of Hoyt’s fraud and asserted various arguments
regarding the appropriateness of an offer-in-compromise.
On May 21, 2004, petitioners submitted another letter to Ms.
Cochran, which included 42 exhibits not provided with the April
9, 2004, letters.
On September 1, 2004, respondent issued petitioners a notice
of determination. In evaluating petitioners’ offer-in-
compromise, respondent made the following changes to the values
of assets reported by petitioners on the Form 433-A: (1)
Determined that the house was worth $214,141 instead of $164,713,
based on the value assigned to the property by the Calaveras
County Assessor’s Office in 2002; (2) included the quick-sale
value of the 1989 Nissan Maxima of $431 instead of the fair
market value petitioners reported; (3) included the quick-sale
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