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value of the boat and carrier of $8,800 instead of the fair
market value petitioners reported; and (4) estimated that the
quick-sale value of the fifth wheel camper was $400. Respondent
did not include the value of the life insurance or the 2002 Ford
F350 because the loans on the items exceeded their value.
Respondent concluded that petitioners had a total net realizable
equity of $234,172.
Respondent accepted petitioners’ reported gross monthly
income of $7,219. Respondent made the following adjustments to
petitioners’ monthly expenses: (1) Reduced the housing and
utilities expense from $1,156 to $726 to reflect the actual
documented costs; (2) reduced the transportation expense from
$1,212 to $758 because Mr. Hubbart’s medical treatments were
completed by the time of the section 6330 hearing and thus an
additional allowance for gas was not needed; (3) reduced medical
expenses from $1,130 to $912 to reflect actual documented out-of-
pocket expenses; and (4) allowed the payments to the State of
California Franchise Tax Board only through July 2007 because
petitioners estimated that their State tax liability would be
paid by that time. Regarding the possible future increases in
expenses outlined in petitioners’ April 9, 2004 letters,
respondent determined that these were “general projections from
the taxpayers’ representative and may never, in fact, be
incurred” and thus did not take them into account.
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