Donald Ertz - Page 19

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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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