Dale L. Oyer, Transferee, et al. - Page 7

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          actions.  In the notices, respondent also determined that                   
          petitioners’ offers in compromise based on doubt as to liability            
          were unacceptable because each petitioner’s underlying tax                  
          liability was based on a Tax Court decision and because each                
          petitioner was noncompliant with income tax filing requirements.            
          In the notices, respondent determined that all applicable legal             
          and administrative procedures had been met and that collection              
          actions could proceed against petitioners.                                  
          H.   The Petitions                                                          
               On July 18, 2002, petitioners filed with the Court                     
          substantially identical petitions challenging the notices.5  In             
          the petitions, petitioners challenge their transferee tax                   
          liabilities and also challenge the Appeals officer’s rejection of           
          their offers in compromise.                                                 
          I.   Respondent’s Motions for Summary Judgment                              
               On January 31, 2003, respondent filed substantially                    
          identical motions for summary judgment in each petitioner’s case.           
          On February 13, 2003, petitioners filed substantially identical             
          responses opposing respondent’s motions for summary judgment in             
          each case.  On February 24, 2003, the Court held a hearing in               



               5 When these petitions were filed, Dale Oyer resided in                
          Kansas City, Missouri, and Shirley Oyer resided in Shawnee,                 
          Kansas.  The petitions for Acme Leasing Trust and ABC Seamless              
          Trust each listed the same Kansas City, Missouri, mailing                   
          address.                                                                    





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