Donald G. and Claudia A. Willis - Page 3

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          2001, petitioners’ counsel met with a settlement officer from               
          respondent’s Appeals Office.  Petitioners’ counsel requested that           
          respondent allow petitioners to partially satisfy their                     
          cumulative liability by means of an installment agreement.                  
               The settlement officer correctly advised petitioners’                  
          counsel that, under respondent’s policy, an installment agreement           
          would be acceptable only if the payments thereunder would satisfy           
          in full the total amount of the cumulative liability within the             
          applicable periods of limitation, plus any allowable extensions.            
          Petitioners did not offer to make payments to respondent in an              
          amount sufficient, within the applicable periods of limitation              
          plus allowable extensions, to fully satisfy the cumulative                  
          liability, which, at that time, totaled approximately $125,000.             
          As a result, respondent rejected petitioners’ proposed                      
          installment agreement.                                                      
          On July 17, 2001, petitioner personally met with the                        
          settlement officer.  At that meeting, petitioner requested that             
          respondent designate the cumulative liability as currently not              
          collectible (i.e., as uncollectible), and the settlement officer            
          considered the revisions petitioner submitted to his financial              
          information.  After considering the revisions, the settlement               
          officer concluded that petitioners had disposable monthly income            
          of $348 and that petitioners could afford to make payment to                
          respondent of $180 per month.  As a result, the settlement                  






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