Roger D. and Mary M. Catlow - Page 19

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          Cochran conducted a thorough review of the documentation                    
          submitted to her by petitioners.  Petitioners acknowledged that             
          they had no “extraordinary health issues” yet claimed monthly               
          health care expenses of $1,103.  Cochran reviewed the Form 433-A            
          and found that petitioners’ only documented health-related                  
          expense was a monthly long-term care insurance premium of $182.             
          Nonetheless, she allowed petitioners a monthly health care                  
          expense of $300.  Although petitioners believe that Cochran’s               
          calculation should have reflected increased medical expenses in             
          the 48-month period and thereafter, we do not agree.  See Fargo             
          v. Commissioner, 447 F.3d at 710 (it is not an abuse of                     
          discretion to disregard claimed medical expenses that are                   
          speculative or not related to the taxpayer).  Moreover, besides             
          their health care expenses, Cochran gave petitioners the benefit            
          of the doubt in other instances as well.  For example, she                  
          accepted petitioners’ claimed values of their vehicles even                 
          though they provided no substantiation of this and also claimed             
          that some of their vehicles had either no or de minimis value.              
          Cochran also accepted petitioners’ valuation of their real estate           
          and mobile home even though they obtained these values from tax             
          assessments and the fair market value of these properties could             
          have been higher.  Although Cochran made some adjustments to some           
          of petitioners’ claimed expenses, she did so in accordance with             
          the Commissioner’s national and local guidelines and after                  






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