Michael J. Heckler, a.k.a. Michael Vonheckler and Charlotte A. Miska - Page 5

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          On December 26, 1995, petitioners filed a petition for                      
          redetermination with the Court.  The petition includes                      
          allegations that the amount in dispute is $8,692.79, that                   
          petitioners paid the tax on July 18, 1994, and that respondent              
          computed the interest incorrectly.                                          
               On February 20, 1996, petitioners paid $3,240.60 which                 
          respondent applied against the $8,692.79 assessment for section             
          6621(c) interest that respondent assessed against petitioners on            
          October 23, 1995.                                                           
          On June 24, 1996, petitioner filed a Motion to Restrain                     
          Assessment and Collection attaching thereto a notice of intent to           
          levy which respondent issued to petitioners on June 10, 1996,               
          demanding payment in the amount of $5,926.35 for the taxable year           
          1986.                                                                       
          Petitioner's motion was called for hearing in Washington,                   
          D.C., on August 28, 1996.  Counsel for respondent appeared at the           
          hearing and was granted leave to file an objection to                       
          petitioner's motion.  Although petitioner did not appear at the             
          hearing, he did file three written statements with the Court                
          pursuant to Rule 50(c).2  Reading petitioner's written statements           
          together, petitioner contends that the $3,240.60 that petitioners           


               2  After the hearing, petitioner filed a response to                   
          respondent's memorandum of law in support of respondent's                   
          objection to petitioner's motion to restrain assessment and                 
          collection.                                                                 




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