Barry and Sherry Blondheim - Page 5

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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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