Janie M. Dixon and Joseph Dixon, Jr. - Page 4

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          Filing and Your Right to a Hearing Under IRC 6320 regarding the             
          just-described lien.  Petitioners returned to respondent a Form             
          12153, Request for a Collection Due Process Hearing, signed by              
          both petitioners and dated January 30, 2001.  Petitioners on the            
          Form 12153 supplied the following explanation of their                      
          disagreement with the lien:  “The wrong SS# was filed in 1997.              
          Joseph did not make[,] work, or receive any money from any                  
          employer.  We contacted the IRS several time [sic] to try & get             
          this corrected.  We even contacted the employer once we found out           
          about this.  Nothing was resolved.”                                         
               Additionally, the record contains a handwritten statement              
          dated February 3, 2001, signed by Ms. Dixon, and apparently                 
          provided to respondent.  Therein, Ms. Dixon further details                 
          circumstances surrounding an allegedly mistaken Form W-2, Wage              
          and Tax Statement, and asserts:  “When I filed my taxes for the             
          year 1997 I knew absolutely nothing about any taxes or wages in             
          my husband [sic] name. * * * I donot [sic] think that I should be           
          held accountable for some thing [sic] I had no knowledge about.”            
               After a telephone conference conducted on October 17, 2002,            
          respondent on January 27, 2003, issued the above-mentioned                  
          Notices of Determination Concerning Collection Action(s) Under              
          Section 6320 and/or 6330 and Notice of Determination Concerning             
          Your Request for Relief from Joint and Several Liability Under              
          Section 6015.  These notices sustained the filing of the notice             






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