Andy Hromiko - Page 3

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               On June 7, 2001, we issued an opinion in MatrixInfoSys Trust           
          v. Commissioner, T.C. Memo. 2001-133, in which we sustained                 
          income tax deficiencies and additions to tax against petitioner             
          as follows:                                                                 
                 Additions to Tax                                                     
               Year      Deficiency     Sec. 6651(a)(1)     Sec. 6654                 
               1994       $20,340           $5,085            $1,055                  
               1995        20,176            5,044             1,094                  
               1996        19,447            4,862             1,035                  
               1997        18,366            4,592               983                  
          In addition, we imposed a penalty under section 6673(a)(1) of               
          $12,500.  All of these amounts shall hereinafter be collectively            
          referred to as the “unpaid liability”.  Decision was entered in             
          MatrixInfoSys Trust on July 9, 2001.  Petitioner subsequently               
          appealed the decision to the Court of Appeals for the Ninth                 
          Circuit.  Petitioner did not file a bond with this Court at the             
          time he filed his Notice of Appeal in that case.                            
               Respondent assessed the unpaid liability plus interest and             
          mailed Statutory Notices of Balance Due with regard thereto on              
          February 25, 2002.  On or about June 6, 2002, respondent sent               
          petitioner a Letter 1058, Final Notice of Intent to Levy and                
          Notice of Your Right to a Hearing, with respect to the unpaid               
               Petitioner timely requested a hearing under section 6330(b).           
          In his request, petitioner asserted that respondent’s collection            
          actions were premature, given that an appeal in MatrixInfoSys               

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