Gary and Johnean Hansen - Page 7

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          adjustment in accordance with respondent’s national guideline               
          amounts based on petitioners’ monthly income and household size.            
          Cochran also considered petitioners’ particular circumstances but           
          noted that they did not warrant allowing the higher figure                  
          submitted by petitioners.  Second, Cochran allowed $1,093                   
          (instead of $1,500) for monthly housing expenses.  She made this            
          adjustment in accordance with respondent’s local guideline                  
          amounts and noted that petitioners had not documented any reason            
          for deviating from these guidelines.  Finally, Cochran allowed              
          $2,100 (instead of $4,000) for monthly tax expenses.  She arrived           
          at this figure by calculating petitioners’ monthly income and               
          determining their approximate monthly tax liability.  She noted             
          that petitioners resided in Washington, which does not have a               
          State income tax.  In sum, Cochran concluded that petitioners had           
          allowable monthly expenses of $5,675.                                       
               Cochran determined that petitioners’ net realizable equity             
          in their assets was either $311,200 or $306,013, see supra                  
          note 7, and that petitioners had a monthly disposable income of             
          $6,265 ($11,940 in monthly income less $5,675 of monthly                    
          allowable expenses).  Cochran also determined that petitioners              
          could pay $300,720 from their future income.9  In sum, Cochran              

               9 Cochran arrived at $300,720 by multiplying petitioners’              
          monthly disposable income of $6,265 by a factor of 48.  Cochran             
          used a 48-month factor because petitioners were offering to                 
          compromise their tax liability by paying cash.  See Internal                

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