- 9 - the likelihood of increased housing and medical costs as petitioner and Mrs. Johnson aged. In the remaining three letters, petitioner alleged that he was a victim of Hoyt’s fraud and asserted various arguments regarding the appropriateness of an offer-in-compromise. On September 29, 2004, respondent issued petitioner a notice of determination. In evaluating petitioner’s offer-in- compromise, respondent made the following changes to the values of assets reported by petitioner on the Form 433-A: (1) Determined that the house was worth $250,000 instead of $81,325; (2) determined that the pasture land was worth $52,651 instead of $26,325; (3) included the full value of petitioner’s and Mrs. Johnson’s retirement accounts instead of their 70-percent value; and (4) included the quick-sale value of the vehicles and the motor home. Respondent determined that petitioner had total net realizable equity in assets of $428,066. Respondent accepted petitioner’s pension and interest income as reported but increased the net rental income from $155 to $165 based on petitioner’s 2003 Federal income tax return. Respondent accepted the majority of petitioner’s monthly expenses, but made the following changes: (1) Reduced the foods, clothing, etc. expense from $904 to $801 to reflect the national standard; (2) reduced the housing expense from $1,254 to $885 to reflect actual documented costs; and (3) disallowed the taxes expense becausePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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