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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, petitioner’s
reasonable collection potential was much greater than his offer
amount ($120,500). We find that Ms. Cochran’s error did not
amount to an abuse of discretion because, even when the error is
corrected, petitioner’s reasonable collection potential of
$442,338 far exceeds his offer amount of $120,500.
With regard to age, health, and retirement status,
petitioner’s argument is not supported by the record. On his
Form 433-A, petitioner reported monthly medical expenses of $322.
In his letter describing the offer amount, petitioner represented
that he and Mrs. Johnson were retired.
Ms. Cochran accepted petitioner’s monthly medical expenses
without change. Because petitioner and Mrs. Johnson were
retired, Ms. Cochran considered only pension income and other
income not contingent upon employment. Given that Ms. Cochran
accepted petitioner’s medical expenses as reported and considered
future income consistent with the retirement considerations
listed by petitioner, we reject petitioner’s assertion that Ms.
Cochran failed to consider his and Mrs. Johnson’s age, health,
retirement status, and current medical costs.
Petitioner’s argument is also unavailing with regard to the
likelihood of future increases in medical and housing costs.
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