- 19 - 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 exceededPage: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
Last modified: May 25, 2011