Rainer B. and Sonja D. Wagner - Page 7

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          includes an IMF MCC3 transcript of account, dated December 18,              
          2000, regarding petitioners’ 1997 taxable year.                             
               On July 30, 2001, the Appeals officer conducted an Appeals             
          Office hearing that petitioner Rainer Wagner attended.  According           
          to a purported transcript of the hearing prepared by petitioners,           
          petitioner Rainer Wagner offered to pay the amount due for 1997             
          only if the Appeals officer would show him the Internal Revenue             
          Code provisions making petitioners liable for Federal income                
          taxes.  The Appeals officer terminated the hearing when                     
          petitioner failed to raise any valid issue.                                 
          E.  Respondent’s Notice of Determination                                    
               On September 21, 2001, respondent sent petitioners a Notice            
          of Determination Concerning Collection Action(s) Under Section              
          6320 and/or 6330.  The notice stated that the Appeals Office had            
          determined that it was appropriate for respondent to proceed with           
          the collection of petitioners’ outstanding tax liability for                
          F.  Petitioners’ Petition                                                   
               On October 17, 2001, petitioners filed with the Court a                
          petition for lien or levy action seeking review of respondent’s             
          notice of determination.4  The petition includes allegations                

               3  IMF MCC stands for “Individual Master File-Martinsburg              
          Computing Center”.                                                          
               4  At the time the petition was filed, petitioners resided             

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