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the arguments and information presented to her. Given the amount
of information, it would be unreasonable to require her to
specifically address in the notice of determination every single
asserted fact, circumstance, and argument presented. The fact
that all of the information presented was not specifically
addressed in the notice of determination does not indicate an
abuse of discretion.
2. Petitioner’s Medical Expenses and Possible
Retirement
Petitioner argues Ms. Cochran failed to adequately consider
his declining health, the likelihood his health problems will
require early retirement, and possible future increases in
medical expenses.
Included in the documentation provided to Ms. Cochran were
letters from petitioner’s doctors stating that he suffers from
work-related injuries to his lumbar, cervical, and thoracic
spine, his wrists, and his right elbow, resulting in multiple
medical procedures, including pain management therapy.
Petitioner asserted the severity of his injuries will force him
to retire in the near future and presented a letter from his
doctor indicating his injuries “may” lead to future disability.
In the notice of determination, Ms. Cochran stated: “the
taxpayer’s representative contended that the taxpayer was being
evaluated for possible disability”. However, no actual
disability was documented, and no evidence was produced
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