Gerry Ashurst - Page 4

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               In response to the Final Notice, petitioners requested a               
          hearing pursuant to section 6330(b) (hearing) on August 7, 2000.            
          On June 8, 2001, Appeals Officer William Smith of the Salt Lake             
          City, Utah Appeals Office (Appeals Officer Smith) sent a letter             
          to petitioners scheduling a hearing for July 12, 2001.  The                 
          hearing was subsequently postponed because petitioners indicated            
          that they would file an OIC with respect to their outstanding tax           
          liabilities.                                                                
               On July 3, 2001, petitioners submitted an OIC for their                
          unpaid income tax liabilities for 1991, 1992, 1993, 1994, 1995,             
          1996, as well as 2000.  On a Form 656, Offer in Compromise,                 
          petitioners indicated that Mr. Ashurst had been unemployed since            
          July of 2000, that he had coronary surgery in August of 1998,               
          that prevented him from engaging in physical activity, and that             
          they had exhausted all their resources in seeking employment and            
          maintaining the household.  Petitioners offered to compromise               
          their tax liabilities of approximately $27,000 for the years 1991           
          through 1996 and 2000 with a one-time payment of $3,500.                    
               On July 9, 2001, Appeals Officer Smith informed petitioners            
          that their offer was received and that an Offer examiner would              
          contact them to evaluate their request.  On January 16, 2002,               
          Bonnie Griggs, a Revenue officer from the Ogden, Utah, Office of            
          the Internal Revenue Service (Revenue Officer Griggs) sent                  
          petitioners a letter stating that the OIC had been reviewed and             






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