Mark Fowler and Joylyn Souter-Fowler - Page 8

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          national statistical averages.  Using $4,644 resulted in                    
          petitioners’ estimated monthly expenses exceeding their monthly             
          income by $36 and rendering petitioners ineligible due to their             
          projected inability to make the $100-monthly payments.                      
               The Appeals officer rejected petitioners’ offers in                    
          compromise.  Petitioners requested an in person hearing, but a              
          hearing was not held due to petitioners’ unavailability.  On                
          February 21, 2002, respondent issued two separate notices of                
          determination for the individual and joint liabilities sustaining           
          the filing of the notices of Federal tax liens and rejecting                
          petitioners’ offers in compromise.  Petitioners timely appealed             
          to this Court for review of respondent’s determinations.                    
               Petitioners contend that the Appeals officer abused his                
          discretion by rejecting their offers in compromise and by                   
          sustaining the filing of the Federal tax liens.                             
               Section 6320 provides that a taxpayer shall be notified in             
          writing by the Secretary of the filing of a Federal tax lien and            
          provided with an opportunity for an administrative hearing.  Sec.           
          6320(b).  Hearings under section 6320 are conducted in accordance           
          with the procedural requirements set forth in section 6330.  Sec.           
               When an Appeals officer issues a determination regarding a             
          disputed collection action, section 6330(d) allows a taxpayer to            

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