Bobbie E. Johnson - Page 18

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          reflected in the notice of determination.  Ms. Cochran testified            
          that the change would not have had an effect on her final                   
          determination because, using either calculation, petitioner’s               
          reasonable collection potential was much greater than his offer             
          amount ($120,500).  We find that Ms. Cochran’s error did not                
          amount to an abuse of discretion because, even when the error is            
          corrected, petitioner’s reasonable collection potential of                  
          $442,338 far exceeds his offer amount of $120,500.                          
               With regard to age, health, and retirement status,                     
          petitioner’s argument is not supported by the record.  On his               
          Form 433-A, petitioner reported monthly medical expenses of $322.           
          In his letter describing the offer amount, petitioner represented           
          that he and Mrs. Johnson were retired.                                      
               Ms. Cochran accepted petitioner’s monthly medical expenses             
          without change.  Because petitioner and Mrs. Johnson were                   
          retired, Ms. Cochran considered only pension income and other               
          income not contingent upon employment.  Given that Ms. Cochran              
          accepted petitioner’s medical expenses as reported and considered           
          future income consistent with the retirement considerations                 
          listed by petitioner, we reject petitioner’s assertion that Ms.             
          Cochran failed to consider his and Mrs. Johnson’s age, health,              
          retirement status, and current medical costs.                               
               Petitioner’s argument is also unavailing with regard to the            
          likelihood of future increases in medical and housing costs.                






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