- 20 - As reflected in the notice of determination, Ms. Cochran took into consideration the information petitioners presented, but concluded that “these possible future expenses are general projections from the taxpayers’ representative and may never, in fact, be incurred. The present offer, therefore, must be considered within the framework of present facts.” Given the information presented to her, it was not arbitrary or capricious for Ms. Cochran to ignore these speculative future costs in making her final determination. Petitioners also raise challenges to various other determinations made by Ms. Cochran, including: (1) The determination that their house had a value of $350,000; (2) the inclusion of 100 percent of the value of the section 401(k) plan account (less estimated tax and penalties); (3) the reduction of their housing and utilities expense; and (4) the disallowance of $460 in other expenses. We need not discuss in detail these and other minor disputes raised by petitioners. Even assuming arguendo that petitioners’ income, expenses, and value of assets should have been accepted as reported, we would not find that Ms. Cochran abused her discretion in rejecting petitioners’ offer-in- compromise. Ms. Cochran testified that, had she accepted the income, expenses, and value of assets as reported, petitioners’ reasonable collection potential would have been $160,146.Page: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
Last modified: May 25, 2011