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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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