Jerry B. and Donna E. Clawson - Page 8

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               to the taxpayer’s property is if the SEC has taken no                  
               steps to perfect its judgment and the Internal Revenue                 
               Service chooses to file a notice of federal tax lien.                  
               On October 23, 2001, Riley received a payment from                     
          petitioners in the amount of $1,000.  Petitioners designated this           
          payment to be applied against their income tax liability for                
          2000, and Riley applied it against that liability.                          
               On December 19, 2001, Riley received a $2,000 payment from             
          petitioners.  This payment was applied to petitioners’ income tax           
          liability for 1999.                                                         
               Petitioners obtained the SEC’s permission to sell their                
          61-foot Hatteras yacht for $550,000 in December 2001.                       
          Petitioners used the proceeds of this sale to pay off the debt              
          that encumbered the yacht (which was listed on their individual             
          CIS as $410,000) and to pay for their living expenses.  None of             
          the proceeds of this sale were used towards the payment of                  
          petitioners’ income tax liabilities for 1999 or 2000.                       
               On February 4, 2002, Riley received two separate payments of           
          $1,000 each from petitioners.  Both payments were applied to                
          petitioners’ income tax liability for 1999.                                 
               On March 19, 2002, Riley received a $2,000 payment from                
          petitioners.  This payment was applied to petitioners’ income tax           
          liability for 1999.                                                         
               On or about April 4, 2002, Riley faxed a message to McKinnon           
          seeking an explanation of how the filing of a Federal tax lien              






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