Franklin and Janetta Hubbart - Page 21

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          determined by the Calaveras County Assessor’s Office in 2002.  We           
          find that Ms. Cochran’s use of the county assessor’s valuation              
          was not arbitrary or capricious.                                            
               Petitioners raise various other challenges and arguments,              
          including:  (1) Ms. Cochran abused her discretion by taking into            
          consideration only future decreases in expenses and not future              
          increases; (2) Ms. Cochran improperly disallowed petitioners’               
          actual housing and utility expenses; and (3) Ms. Cochran                    
          improperly disallowed petitioners’ actual transportation                    
          expenses.  We need not discuss in detail these and other minor              
          disputes raised by petitioners.  Even assuming arguendo that                
          petitioners’ income, expenses, and value of assets should have              
          been accepted as reported, we would not find that Ms. Cochran               
          abused her discretion in rejecting petitioners’ offer-in-                   
          compromise.  Ms. Cochran testified that, had she accepted the               
          income, expenses, and value of assets as reported, petitioners’             
          reasonable collection potential would have been $178,656.                   
          Petitioners offered to pay only $60,400 to compromise their                 
          outstanding tax liability.  In some situations, respondent may              
          accept an offer amount of less than petitioners’ reasonable                 
          collection potential.  However, given all other considerations              
          discussed herein, we do not believe that Ms. Cochran abused her             
          discretion by rejecting an offer-in-compromise that bore no                 







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