Roy and Margaret Eliason - Page 2




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               Unless otherwise indicated, all section references are to              
          the Internal Revenue Code as applicable to the years in issue.              
               Hereinafter, references to petitioner in the singular are to           
          petitioner Roy Eliason.                                                     

                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
               At the time the petition was filed, petitioners resided in             
          O’Fallon, Missouri.                                                         
               Petitioners’ undisputed and unpaid Federal income tax                  
          liabilities including penalties and interest, as of October 1,              
          2001, total $1,902 for 1994 and $5,254 for 1995.                            
               On May 22, 1999, respondent mailed to petitioners a notice             
          of intent to levy and a notice of petitioners’ right to a                   
          collection hearing with respondent’s Appeals Office relating to             
          petitioners’ income tax liabilities for 1994 and 1995.                      
               On June 14, 1999, respondent received from petitioners a               
          request for a collection hearing with respondent’s Appeals                  
          Office.                                                                     
               On May 20, 2000, in connection with the above request by               
          petitioners for a collection hearing, petitioners submitted to              
          respondent’s Appeals Office a financial statement showing with              
          respect to petitioners’ monthly income and expenses a net income            
          of $1,914.  After adjustments were made by respondent’s Appeals             
          Office increasing the amount of petitioners’ monthly expenses,              





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