Estate of Carol Andrews, Deceased, Robert Andrews, Special Administrator, and Robert Andrews - Page 17

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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 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’             

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