- 6 -
Cochran determined that petitioners’ net realizable equity
in their cash was the $3,600 reported in their bank accounts and
that petitioners’ net realizable equity in their real estate and
vehicles was the same as the reported values (as reduced by the
related liabilities), except she reduced the reported value of
each vehicle by 20 percent to reflect their “quick sale values”.7
As to the retirement account, Cochran noted that petitioners’
representative had informed her that the value of the account was
reported at 15 percent less than the actual value in order to
reflect taxes and concluded that the full value of the retirement
account was $385,992.8 Alternatively, Cochran determined, the
value of the retirement account was $270,992 after subtracting
from the $385,992 a withdrawal of $115,000 to pay petitioners’
$100,000 proposed offer and related taxes at 15 percent. Cochran
summarized petitioners’ assets and liabilities as follows:
7 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”.
8 We are unable to determine the specifics underlying
Cochran’s calculation of the $385,992.
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