- 20 - his income and therefore concluded that petitioner could not fund the offer-in-compromise with future income until the mortgage on his home was paid off.11 Given her acceptance of the medical expenses as reported and her conclusion that petitioner would not have future income to fund the offer-in-compromise until the mortgage on his home was paid off, we reject petitioner’s assertion that Ms. Cochran failed to consider petitioner’s and Mrs. Ertz’s age, health, retirement status, and current medical costs. Petitioner’s argument is also unavailing with regard to the likelihood of future increases in medical and housing costs. Petitioner did not inform Ms. Cochran with any specificity that he would have to pay a greater amount of unreimbursed medical expenses in the future, or that his housing expenses would increase. Instead, he made general assertions about the increase of medical costs as people age and about the need for some seniors to seek in-home care or nursing home care or to make their house handicapped accessible. As reflected in the notice of determination, Ms. Cochran took into consideration the information petitioner presented but 11 While Ms. Cochran determined that petitioner could not otherwise fund the offer-in-compromise with future income, she determined that there was an “amount collectible from retired debt”. Because petitioner’s mortgage would be paid off within 4 years, Ms. Cochran determined that the amount of the monthly mortgage payment, less the deficit between income and expenses, could then be applied to petitioner’s outstanding tax liability.Page: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
Last modified: May 25, 2011