Jerry B. and Donna E. Clawson - Page 2

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          discretion by sustaining a proposed levy to collect petitioners’            
          unpaid income tax liabilities for 1999 and 2000.                            
               Unless otherwise indicated, all section references are to              
          the Internal Revenue Code as amended, and all Rule references are           
          to the Tax Court Rules of Practice and Procedure.  All amounts              
          have been rounded to the nearest dollar.                                    
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated, and the stipulated             
          facts are incorporated in our findings by this reference.  At the           
          time that the petition in this case was filed, petitioners                  
          resided in Cape Coral, Florida.                                             
          Background                                                                  
               Petitioners filed their joint Federal income tax return for            
          1999 on or about October 15, 2000, and their joint Federal income           
          tax return for 2000 in October 2001 showing balances due.  As of            
          July 17, 2002, petitioners’ unpaid income tax liabilities for               
          1999 and 2000, including accruals of interest and penalties,                
          exceeded $385,000 and $64,000, respectively.                                
               In March 2001, petitioners retained a certified public                 
          accountant, David B. McKinnon (McKinnon), to represent them                 
          before the Internal Revenue Service (IRS) in connection with the            
          collection of their tax liabilities.  On or about March 28, 2001,           
          petitioners filed a Form 2848, Power of Attorney and Declaration            








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