Estate of Carol Andrews, Deceased, Robert Andrews, Special Administrator, and Robert Andrews - Page 18

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          only 48 months of future income should be considered.                       
          Petitioners made a cash offer, but Ms. Cochran used 81 months of            
          future income.  At trial, Ms. Cochran acknowledged that she                 
          should have used only 48 months of future income.  Ms. Cochran              
          recomputed petitioners’ reasonable collection potential using 48            
          months and determined that it was $351,531, instead of $380,076,            
          as reflected in the notice of determination.  Ms. Cochran                   
          testified that the change would not have had an effect on her               
          final determination because, using either calculation,                      
          petitioners’ reasonable collection potential was greater than               
          their offer amount ($25,000).  We find that Ms. Cochran’s error             
          did not amount to an abuse of discretion because, even when the             
          error is corrected, petitioners’ reasonable collection potential            
          of $351,531 far exceeds their offer amount of $25,000.                      
               With regard to age, health, and retirement status,                     
          petitioners’ argument is not supported by the record.  In their             
          letter describing their offer amount, petitioners represented               
          that Mrs. Andrews was retired and Mr. Andrews would retire when             
          he reached 65 years old.  Petitioners also indicated that they              
          suffered from various medical conditions and that Mrs. Andrews              
          was taking several medications.  On their Form 433-A, petitioners           
          reported monthly medical expenses of $533.                                  
               Ms. Cochran accepted petitioners’ monthly medical expenses             
          without change.  Ms. Cochran also accepted petitioners’                     

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