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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.
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