Nita B. Leissner - Page 4

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          issued a check in the amount of $19,980.69 to the Internal                  
          Revenue Service in response to the notice of levy.                          
               On January 7, 1997, the aforementioned $19,980.69 was                  
          allocated to petitioner and Mr. Leissner’s 1986 and 1987 tax                
          liabilities as follows:  $8,710.27 was applied to the 1986 tax              
          liability and $11,270.42 was applied to the 1987 tax liability.             
               The parties stipulated that the application of $11,270.42 to           
          the 1987 tax liability fully paid the tax, penalties, and                   
          interest due for 1987.  The parties agree that a lien filing fee            
          of $32 relating to 1987 was not paid along with the tax,                    
          penalties, and interest for 1987.  The parties do not agree as to           
          whether the lien filing fee is part of petitioner’s 1987 tax                
          liability.                                                                  
               On March 3, 1997, petitioner filed for Chapter 7 bankruptcy            
          relief.  On July 9, 1997, petitioner received a personal                    
          discharge from liability for her 1986 and 1987 income tax                   
          liabilities.                                                                
               Mr. Leissner did not pay the 1986 tax liabilities prior to             
          July 22, 1998.                                                              
               As of July 22, 1998, petitioner and Mr. Leissner had an                
          outstanding income tax liability of $65,905.43 for 1986.  As of             
          July 22, 1998, a lien filing fee of $32 was outstanding for 1987.           
               On November 30, 1998, petitioner filed Form 911, Application           
          for Taxpayer Assistance Order, seeking a refund of the money                






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