Dennis Stewart - Page 2

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                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the attached exhibits are                      
          incorporated herein by this reference.  At the time he filed the            
          petition, petitioner resided in Michigan.                                   
               Around March 1994, the Internal Revenue Service (IRS)                  
          audited petitioner for 1990 and 1992.  The audit resulted in                
          proposed increases in petitioner’s income tax liabilities for               
          those years.  Petitioner knew that he could have appealed the               
          proposed increases, but instead he agreed to them.                          
               On March 14, 2000, respondent mailed petitioner, via                   
          certified mail, a Final Notice, Notice of Intent to Levy and                
          Notice of Your Right to a Hearing, with regard to his unpaid tax            
          liabilities for 1990 through 1998.                                          
               On or about April 10, 2000, respondent received from                   
          petitioner a timely Request for a Collection Due Process Hearing,           
          Form 12153, (hearing request) with attachments.  In the hearing             
          request, petitioner stated:                                                 
               Petitioner admits that a certain obligation for taxes                  
               due the Internal Revenue Service exists, but denies any                
               and all responsibility for said obligation for the                     
               reason that a prior assignment of a lien and its                       
               proceeds by Petitioner as grantor in favor of the                      
               United States and the IRS as a grantee was extinguished                
               contrary to U.S. law through unlawful mortgage                         
               foreclosure proceeding concluded on December 15, 1994.                 
               Additionally, the mortgage foreclosed upon was a                       
               forgery.  It appears that the proceeds of these crimes                 
               (proceeds which by prior tax liability are the                         
               legitimate property of the United States), are                         

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