Donald G. and Claudia A. Willis - Page 4

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          officer advised petitioners that the cumulative liability could             
          not be classified as currently not collectible.  The settlement             
          officer then suggested to petitioner that petitioners submit an             
          offer in compromise in the amount of $180 per month for 116                 
          months.  Under this suggested offer in compromise, respondent               
          would consider compromising the cumulative liability for a total            
          payment by petitioners of $20,880.                                          
               On or about September 5, 2001, petitioners submitted on the            
          appropriate form the above offer in compromise as proposed by               
          respondent’s settlement officer.  On September 18, 2001, the                
          settlement officer wrote to petitioners indicating that                     
          verification of the financial information petitioners had                   
          submitted was required before petitioners’ offer in compromise              
          could be reviewed and approved.                                             
               During the settlement officer’s verification of petitioners’           
          financial information, certain real estate was identified which             
          had not been previously disclosed to respondent.3  Petitioners’             
          mobile home in which they resided was located on the real estate.           
          In 1996, the real estate had been purchased in petitioners’                 
          names, using a cashier’s check in the amount of $8,750 as part of           
          a $9,000 downpayment toward the $35,000 total purchase price.  In           
          1998, nominal title to this real estate was transferred by                  


               3  The information that petitioners had submitted up until             
          that time indicated that petitioners paid rent for the “land” on            
          which the mobile home in which they resided was located.                    





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