Roger and Lora Carter - Page 20

                                       - 20 -                                         
          income from wages, we reject petitioners’ assertion that Ms.                
          Cochran failed to consider each petitioner’s 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.                                        
               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 assert that Ms. Cochran abused her                    
          discretion by using Mr. Carter’s pension in her calculation of              
          petitioners’ future income.  Petitioners argue that they must               






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