Estate of Carol Andrews, Deceased, Robert Andrews, Special Administrator, and Robert Andrews - Page 19

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          representation that Mrs. Andrews was retired, and thus only                 
          considered her future income from pension/Social Security.  While           
          petitioners indicated that Mr. Andrews would retire at 65, he was           
          only 59 at the time of the section 6330 hearing.11  Thus, based             
          on the information submitted by petitioners, Mr. Andrews would              
          continue to work for at least 5 to 6 more years.  Given that Ms.            
          Cochran accepted petitioners’ medical expenses as reported and              
          considered future income consistent with the retirement                     
          considerations listed by petitioners, we reject petitioners’                
          assertion that Ms. Cochran failed to consider petitioners’ age,             
          health, retirement status, and current medical costs.                       
               Petitioners’ argument is also unavailing with regard to the            
          likelihood of future increases in medical and housing costs.                
          Petitioners did not inform Ms. Cochran with any specificity that            
          they would have to pay a greater amount of unreimbursed medical             
          expenses in the future, or that their housing expenses would                
          increase.  Instead, they made general assertions about the                  
          increase of medical costs as people age and about the need for              
          some seniors to seek in-home care or nursing home care or to make           
          their houses handicapped accessible.                                        

               11  In the letter explaining the offer amount, petitioners             
          stated that Mr. Andrews was 62 instead of 59.  However,                     
          petitioners listed Mr. Andrews’s date of birth as September 5,              
          1944, which would mean that he was 59 years old on March 17, 2004           
          (the date of the sec. 6330 hearing).                                        

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