David M. Leggett - Page 9

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               In March 1996, petitioner and an unidentified individual               
          visited (March 1996 meeting) the office of a revenue officer of             
          the Service (revenue officer) who was responsible for conducting            
          investigations of delinquent returns and collecting unpaid taxes.           
          Petitioner asked the revenue officer for permission to tape the             
          March 1996 meeting, but the revenue officer declined because the            
          revenue officer did not have equipment readily available with               
          which he also could have taped that meeting.  However, the                  
          revenue officer informed petitioner that if petitioner were to              
          give him 10 days' written notice, he could arrange another                  
          meeting that could be taped.  Petitioner informed the revenue               
          officer at the March 1996 meeting that there were certain civil             
          penalties that he wanted to have abated by the Service that arose           
          from his having submitted Forms 1040NR.  The revenue officer                
          asked petitioner at the March 1996 meeting if he was a U.S.                 
          citizen or a nonresident alien.  Petitioner responded that he was           
          both.  The revenue officer told petitioner that he had to be one            
          or the other, but that he could not be both.                                
               The revenue officer also advised petitioner at the March               
          1996 meeting that the Service's records indicated that he had not           
          filed returns for 1992, 1993, and 1994 and that the Service had             
          records from payors of income to petitioner, which indicated that           
          petitioner had substantial income for those years.3  Petitioner             

               3  As of the time of the March 1996 meeting, petitioner's              

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