Franklin and Janetta Hubbart - Page 19

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               With regard to age, health, and retirement status,                     
          petitioners’ argument is not supported by the record.  In the               
          information submitted to Ms. Cochran, petitioners represented               
          that they were retired and, due to their medical conditions,                
          could not obtain employment.  Ms. Cochran did not dispute this.             
          In calculating petitioners’ reasonable collection potential, she            
          used only their reported pension income.                                    
               Ms. Cochran allowed only $912 of petitioners’ reported                 
          monthly medical expenses of $1,130.  As reflected in the notice             
          of determination, the allowable medical expenses were “based on             
          documentation for out-of-pocket expenses provided by                        
          [petitioners] and reflect costs for February 2003 through March             
          2004 (14 months).  The [petitioners’] expenses totaled $12,756,             
          which, divided by 14 months, equals $911.14.”  While petitioners            
          dispute the reduction of their allowable medical expenses, they             
          have not disputed the accuracy of Ms. Cochran’s determination               
          that petitioners’ actual documented monthly medical expenses were           
          only $912.                                                                  
               Given her inclusion of pension income as the only source of            
          future income and her acceptance of petitioners’ documented                 
          medical expenses, we reject petitioners’ assertion that Ms.                 
          Cochran failed to consider their age, health, retirement status,            
          and current medical costs.                                                  







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