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one of their pension plans. The Form 433-A reported the
following monthly items of income and expense:
Items of income Amount
Husband’s wages $3,700
Wife’s wages 2,500
Rental income 4,434
10,634
Items of expense Amount
Food, clothing, and miscellaneous $1,280
Housing and utilities 1,953
Transportation 596
Medical expenses 669
Taxes 2,250
6,748
Cochran determined that petitioners’ net realizable equity
in their cash was the $46,441 reported in their bank accounts and
that petitioners’ net realizable equity in their life insurance,
Subaru Brat, and Oregon property was the same as the reported
values.4 Cochran noted the various encumbrances reported by
petitioners, and in the case of the furniture/personal effects,
allowed a $7,200 exemption for their entire value under section
6334(a)(2).5 She summarized petitioners’ assets and liabilities
as follows:
4 Cochran was told by petitioners that they had ascertained
the value of each vehicle by using its trade-in value and
considering its condition to be “fair.”
5 Whereas sec. 6334(a)(2) limits this exemption to $6,250,
Cochran does not explain in the notice of determination why she
allowed petitioners the greater amount.
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Last modified: May 25, 2011