Russell L. and Ruth C. Voorhees - Page 2

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               On August 21, 2001, respondent issued to petitioners a Final           
          Notice of Intent to Levy and Notice of Your Right to a Hearing              
          (notice of intent to levy) concerning unpaid joint income tax               
          liabilities for the years 1991 and 1996.  The notice of intent to           
          levy stated that petitioners owed a total of $5,743.04 and                  
          informed petitioners that they had 30 days to pay this amount,              
          make alternative arrangements to pay or request Appeals                     
          consideration and that if petitioners failed to take such action            
          timely, respondent might take their property or rights to                   
               On August 23, 2001 petitioner Russell L. Voorhees signed IRS           
          Form 12153, a Request for a Collection Due Process Hearing                  
          (request for hearing), relating to the tax liabilities.                     
          Petitioner Ruth C. Voorhees did not sign the request for hearing,           
          although her name is listed on the form as a taxpayer.  On August           
          28, 2001, respondent received the request for hearing, and on               
          January 24, 2002, the Internal Revenue Service Office of Appeals            
          (Appeals Office) held a hearing.                                            
               On March 14, 2002, the Appeals Office issued to petitioner             
          Russell L. Voorhees a Notice of Determination concerning                    
          Collection Action(s) under Section 6320 and/or 6330 (notice of              
          determination).  The Appeals Office did not issue a notice of               
          determination to petitioner Ruth C. Voorhees.                               

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