Roger and Lora Carter - Page 21

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          retain the money received from the pension to pay for future                
          increases in expenses.  As discussed above, petitioners’                    
          assertions regarding future expenses are speculative and                    
          unsupported, and it was not arbitrary or capricious for Ms.                 
          Cochran to ignore such costs.  The use of Mr. Carter’s monthly              
          pension payments in calculating petitioners’ reasonable                     
          collection potential was not arbitrary or capricious.                       
               Petitioners also raise challenges to various other                     
          determinations made by Ms. Cochran, including:  (1) The increase            
          of petitioners’ wages from the amounts reported; (2) the                    
          reduction of their housing expense and tax expense; and (3) the             
          disallowance of $600 in monthly insurance payments.15  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 $173,406.  This amount                 

               15  The monthly insurance payments were not reported by                
          petitioners on their Form 433-A, but instead were discussed in              
          their May 14, 2004, letter regarding the offer amount.                      
          Petitioners were covered by insurance through Mr. Carter’s                  
          employment.  However, they would not be covered once he retired.            
          Apparently, the $600 payment reflects petitioners’ estimate of              
          their monthly insurance payments once Mr. Carter retires.                   




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