Roger and Lora Carter - Page 8

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          The reported value of the house reflected an 80-percent “quick-             
          sale” value.  Petitioners also reported that Mr. Carter had a               
          pension fund valued at $123,591, but indicated that it was not              
          currently accessible.                                                       
               Petitioners reported gross monthly income of $4,458,                   
          representing Mr. Carter’s wages of $3,496, Ms. Carter’s wages of            
          $827, and other income of $135.8  Petitioners also reported the             
          following monthly living expenses:                                          

                Expense item               Monthly Expense                            
                Housing                    $1,648                                     
                Transportation             390                                        
                Health care                212                                        
                Taxes                      1,210                                      
                Life insurance             56                                         
                Attorney’s fees            299                                        
                Other business-related     176                                        
                expenses                                                              
                Total                      3,991                                      

               In one of the May 14, 2004 letters, petitioners state that             
          they are offering to pay $99,851 “for all Hoyt related years to             
          be paid in one lump sum payment.  The amount accounts for all the           


               8  The Form 433-A in evidence does not include page 6, which           
          would include “Section 9, Monthly Income and Expense Analysis”              
          and the signature line.  Thus, our findings of fact regarding               
          petitioners’ monthly income and expenses come from                          
          representations made by respondent in the Notice of                         
          Determination.                                                              




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