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MR. CAPLE: Future credits.
THE COURT: Well, suppose if, God forbid, both
of you passed away, there would be
no credits.
MS. CAPLE: Right. That’s right. It’s not
like you’re going to need them.
MR. CAPLE: We would like to apply some of
that * * *.
On the basis of the foregoing exchange and Ms. Roberts’s
testimony explaining why she could not consider “future credits”
as part of petitioners’ OIC, we consider this portion of
petitioners’ OIC to be no more than an irrelevant and misguided
attempt on their part to satisfy their outstanding tax liability.
Ms. Roberts did not abuse her discretion in rejecting this
portion of petitioners’ OIC.
Finally, and with respect to petitioners’ argument that Ms.
Roberts refused to consider factors illustrating petitioners’
economic hardship and extraordinary medical expenses, we are
unpersuaded, on the basis of the foregoing discussion of
petitioners’ assets, that petitioners were unable to pay the
$14,670.74 owed at the time of the hearing. Second, the record
reflects only one letter, dated January 17, 1995, regarding Mr.
Caple’s medical condition. Petitioners have provided no
additional evidence, aside from their statements (which were
neither substantive nor credible), to indicate the impact of
either Mr. Caple’s or Ashley’s medical expenses, although they
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