- 19 -
Petitioner did not inform Ms. Cochran with any specificity that
he would have to pay a greater amount of unreimbursed medical
expenses in the future, or that his housing expenses would
increase. Instead, he 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 petitioner presented, but
concluded that “these possible future expenses are general
projections from the taxpayer’s 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.
Petitioner also raises challenges to various other
determinations made by Ms. Cochran, including: (1) The
determination that the house was worth more than what petitioner
reported; (2) the determination that the pasture land was worth
more than what petitioner reported; and (3) the reduction of his
food, clothing, etc., housing, and tax expenses. We need not
discuss in detail these and other minor disputes raised by
petitioner. Even assuming arguendo that petitioner’s income,
Page: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 NextLast modified: May 25, 2011