Donald G. and Claudia A. Willis - Page 2

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          determination relates to petitioners’ Federal income tax                    
          liabilities for 1992, 1993, 1994, 1995, 1996, and 1997.                     
          Petitioners’ liability for the underlying taxes, interest, and              
          penalties is not disputed.  The issue for decision is whether               
          respondent’s rejection of petitioners’ three proposed                       
          alternatives to collection constitutes an abuse of discretion.              

                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
               At the time of filing the petition, petitioners resided in             
          Lebanon, Tennessee.  Petitioner Donald G. Willis2 operates a                
          locksmith business as a sole proprietorship.  Petitioner                    
          subcontracts much of the locksmith work.  In addition, petitioner           
          derives income from a part-time ministry.  Petitioner Claudia A.            
          Willis is not employed outside the home.                                    
               On January 30, 2001, respondent sent to petitioners a final            
          notice of intent to levy with respect to petitioners’ outstanding           
          Federal income taxes, interest, and penalties for 1992 through              
          1997 (cumulative liability).  On March 1, 2001, respondent                  
          received petitioners’ timely request for a collection due process           
          hearing.                                                                    
               After submitting to respondent for consideration certain               
          personal financial information relating to petitioners, on May 9,           


               2  Hereinafter, unless otherwise indicated, references to              
          petitioner in the singular are to petitioner Donald G. Willis.              





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