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petitioner provided Ms. Cochran with multiple letters and
hundreds of pages of exhibits. As discussed below, Ms. Cochran
considered all of the arguments and information presented to her.
Given the amount of information, it would be unreasonable to put
the burden on Ms. Cochran to specifically address in the notice
of determination every single asserted fact, circumstance, and
argument presented. The fact that all of the information was not
specifically addressed in the notice of determination does not
indicate an abuse of discretion.
2. Petitioner’s Income and Future Expenses
Petitioner argues that Ms. Cochran failed to adequately
consider his and Mrs. Ertz’s age, health, and retirement status,
the likelihood of future increases in medical and housing costs,
and the need to retain retirement assets to cover the difference
between income and expenses. Petitioner’s argument is not
supported by the record.
On his Form 433-A, petitioner reported monthly medical
expenses of $511. Ms. Cochran accepted that amount without
reservation. Ms. Cochran also determined that petitioner and
Mrs. Ertz were unable to obtain employment because of their age
and medical condition. In determining whether petitioner could
fund the offer-in-compromise with future income, Ms. Cochran used
only the monthly pension income reported on the Form 433-A. Ms.
Cochran determined that petitioner’s monthly expenses exceeded
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