Dennis Stewart - Page 3

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               presently in the possession of individuals by name of                  
               Henry Soet and Daniel Bylenga, and a corporation doing                 
               business as Fleet Financial Group.  Furthermore, said                  
               proceeds are more than enough to satisfy any claim for                 
               unpaid taxes purported against Petitioner.                             
          Petitioner’s statement continued for an additional three pages              
          alleging criminal conduct by numerous judges, individuals, and              
          entities.  Additionally, petitioner attached nearly 100 pages of            
          documents to the hearing request regarding the alleged criminal             
          conduct by various judges, individuals, and entities.                       
               On June 23, 2000, the IRS provided petitioner with a section           
          6330 hearing.  Appeals Officer Bruce Skidmore held the conference           
          with petitioner telephonically.  Petitioner’s argument centered             
          on petitioner’s prior lawsuits against Fleet Finance, Inc.                  
          (Fleet), and numerous other entities and individuals regarding              
          Fleet’s foreclosure on a home owned by petitioner at 2625                   
          Emerson, Grand Rapids, Michigan (the Emerson house).  Petitioner            
          claimed that the proceeds of the alleged unlawful mortgage                  
          foreclosure, which all went to Fleet, should have paid off the              
          liabilities at issue because the United States had a second lien            
          on the Emerson house.                                                       
               During the hearing, Mr. Skidmore asked petitioner about his            
          underlying liabilities.  Petitioner stated that he did not                  
          believe that there was any error in the assessments.  Petitioner            
          did not raise any spousal defenses or offer alternative means of            

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