Michael D. Keown and Rosann C. Keown - Page 4

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          Appeals Office (settlement officer) held an Appeals Office                  
          hearing with petitioner Michael D. Keown (Mr. Keown)4 with re-              
          spect to the notice of intent to levy.  At the Appeals Office               
          hearing, the settlement officer gave Mr. Keown Form 4340, Certif-           
          icate of Assessments, Payments, and Other Specified Matters, with           
          respect to petitioners’ taxable year 1999.                                  
               On September 12, 2002, the Appeals Office issued a notice of           
          determination concerning collection action(s) under section 6320            
          and/or 6330 (notice of determination) to Mr. Keown and a separate           
          notice of determination to Ms. Keown.  (We shall refer collec-              
          tively to those two notices as petitioners’ notices of determina-           
          tion).  An attachment to each such notice of determination stated           
          in pertinent part:                                                          
               What is the Issue?                                                     
               The taxpayers requested a hearing under the provisions                 
               of IRC 6330 to contest the intent to levy notice,                      
               Letter LT-11.                                                          
               Verification of Legal and Procedural Requirements                      
               The Secretary has provided sufficient verification that                
               all legal and procedural requirements have been met.                   
               Appeals has reviewed computer transcripts verifying the                
               An assessment was made and the taxpayers were issued                   
               notice and demand letters by regular mail, to the                      
               taxpayers’ last known address, as required under IRC                   
               6303.  They neglected or refused to pay.  The notices                  
               required under IRC 6331(d) and IRC 6330 were combined                  

               4Petitioner Rosann C. Keown (Ms. Keown) did not appear at              
          the Appeals Office hearing held on Aug. 28, 2002.                           

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