Keith and Cherie Orum - Page 3

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               The issues for decision are:  (1) Whether the Court lacks              
          jurisdiction under section 6330(d)(1)1 with regard to 1998; and             
          (2) whether there was an abuse of discretion in the determination           
          that the proposed collection action for 1999 should be sustained.           
                                     Background                                       
               Some of the facts have been stipulated.  The stipulated                
          facts and the attached exhibits are incorporated herein by this             
          reference.                                                                  
               At the time of the filing of the petition, petitioners                 
          resided in La Grange Park, Illinois.  Mr. Orum has lived at the             
          same address his entire life.  Mr. Orum is a patent attorney, and           
          Mrs. Orum is a zookeeper.                                                   
               Petitioners filed joint Federal income tax returns for 1998            
          and 1999 on November 29, 1999, and November 20, 2000,                       
          respectively, but did not make full payments of the tax                     
          liabilities when the returns were filed.                                    
               On November 29, 1999, respondent assessed tax liabilities of           
          $63,683 plus additions to tax for 1998.  Respondent issued                  
          petitioners three notices of demand for payment of the 1998 tax             
          liabilities and additions to tax on November 29, 1999, January 3,           
          2000, and February 7, 2000.                                                 



               1  Unless otherwise indicated, all section references are to           
          the Internal Revenue Code, as amended.  Amounts are rounded to              
          the nearest dollar.                                                         




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