Alan M. and Marcia F. Schulman - Page 13

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          submitted.8  We do not find that the settlement officer abused              
          her discretion in disallowing petitioners’ claimed expenses.                
               The settlement officer was entitled to rely on the standards           
          applicable to Milwaukee County.  Petitioner husband admitted at             
          trial that both he and his wife lived and worked in Milwaukee               
          County.  Petitioners did not introduce any evidence of any                  
          meaningful ties to Ozaukee County, other than the relative                  
          proximity of their residence.  We cannot agree that the                     
          settlement officer abused her discretion in relying on the                  
          housing and utility standards applicable to Milwaukee County.               
          And, it was not an abuse of discretion for her to refuse to                 
          accept what petitioners claimed to be their actual housing and              
          utility expenditures.  The expenses claimed by petitioners                  
          exceeded the applicable local standards for housing and                     

               8Petitioners now propose additional amounts of medical                 
          expenses, increasing their total to $726, as well as an increase            
          in the tax expenses allowed from $1,685 to $2,065.  We decline to           
          discuss those additional amounts, since they were not raised                
          before the settlement officer and were not raised at trial.  “It            
          is the responsibility of the taxpayer to raise all relevant                 
          issues at the time of the pre-levy hearing.”  H. Conf. Rept. 105-           
          599, at 266 (1998), 1998-3 C.B. 755, 1020.  In addition,                    
          petitioners have submitted with their brief a revision of the               
          expenses used by the settlement officer which shows total                   
          expenses of $7,071.  Petitioners propose “a monthly payment of              
          $300 as a way of settling this case”.  Again, this revision is              
          relevant, for purposes of our review, only to the extent it was             
          proposed to the settlement officer.                                         

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