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Petitioners’ argument is also unavailing with regard to the
likelihood of future increases in medical and housing costs.
Petitioners did not inform Ms. Cochran with any specificity that
they would have to pay a greater amount of unreimbursed medical
expenses in the future, or that their housing expenses would
increase. Instead, they 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 houses handicapped accessible.
As reflected in the notice of determination, Ms. Cochran
took into consideration the information petitioners presented,
but concluded that “these possible future expenses are general
projections from the taxpayers’ representative and may never, in
fact, be incurred. The present offer, therefore, must be
considered within the framework of present facts.” Given the
information presented to her, it was not arbitrary or capricious
for Ms. Cochran to ignore these speculative future costs in
making her final determination.
Petitioners dispute Ms. Cochran’s determination that their
house was worth $214,141 instead of $164,713. They argue that,
if Ms. Cochran did not agree with their reported value, she
should have hired a professional valuation expert instead of
making her own determination. Ms. Cochran did not arbitrarily
assign a value to petitioners’ house, but instead used the value
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