Bobbie E. Johnson - Page 9

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          the likelihood of increased housing and medical costs as                    
          petitioner and Mrs. Johnson aged.                                           
               In the remaining three letters, petitioner alleged that he             
          was a victim of Hoyt’s fraud and asserted various arguments                 
          regarding the appropriateness of an offer-in-compromise.                    
               On September 29, 2004, respondent issued petitioner a notice           
          of determination.  In evaluating petitioner’s offer-in-                     
          compromise, respondent made the following changes to the values             
          of assets reported by petitioner on the Form 433-A:  (1)                    
          Determined that the house was worth $250,000 instead of $81,325;            
          (2) determined that the pasture land was worth $52,651 instead of           
          $26,325; (3) included the full value of petitioner’s and Mrs.               
          Johnson’s retirement accounts instead of their 70-percent value;            
          and (4) included the quick-sale value of the vehicles and the               
          motor home.  Respondent determined that petitioner had total net            
          realizable equity in assets of $428,066.                                    
               Respondent accepted petitioner’s pension and interest income           
          as reported but increased the net rental income from $155 to $165           
          based on petitioner’s 2003 Federal income tax return. Respondent            
          accepted the majority of petitioner’s monthly expenses, but made            
          the following changes:  (1) Reduced the foods, clothing, etc.               
          expense from $904 to $801 to reflect the national standard; (2)             
          reduced the housing expense from $1,254 to $885 to reflect actual           
          documented costs; and (3) disallowed the taxes expense because              






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