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considered all of the arguments and information presented to her.
Given the amount of information, it would be unreasonable to put
the burden on Ms. Cochran to specifically address in the notice
of determination every single asserted fact, circumstance, and
argument presented. The fact that all of the information was not
specifically addressed in the notice of determination was not an
abuse of discretion.
2. Petitioners’ Income and Future Expenses
Petitioners assert that Ms. Cochran erroneously determined
their reasonable collection potential by: (1) Considering 81
months of petitioners’ future income instead of 48 months; and
(2) failing to adequately consider their age, health and
retirement status, medical costs, and the likelihood of future
increases in medical and housing costs.10 Petitioners’ arguments
are not persuasive.
Section 5.8.5.5 of the IRM provides that, when a taxpayer
makes a cash offer to compromise an outstanding tax liability,
10 Additionally, petitioners argued on brief that Mr.
Andrews has incurred additional costs arising from the illness
and death of Mrs. Andrews. Petitioners cite Exhibit 427-P, an
explanation of benefits from their insurance provider, as support
for this argument. However, Exhibit 427-P was not offered for
the truth of the matter asserted but was used only to show Mr.
Andrews’s understanding of what his medical bills might be.
Further, Mr. Andrews testified that he was unsure as to how much,
if any, of the medical bills he would ultimately be liable for.
Because there is no evidence in the record that establishes Mr.
Andrews will incur any additional costs, we reject petitioners’
argument.
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