Bradley M. and Monica Pixley - Page 3

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          petitioners filed their petition, they resided in Newhall,                  
          California.                                                                 
               Mr. Pixley is a licensed and ordained Baptist minister.                
          From September 1995 through June 2001, he served as pastor of               
          Grace Community Bible Church, in Tomball, Texas.3  Thereafter,              
          petitioners moved to California, and Mr. Pixley was employed as             
          an echocardiographer at Children’s Hospital in Los Angeles.                 
               Respondent mailed to petitioners a Letter 1058, Final                  
          Notice-Notice of Intent to Levy and Notice of Your Right to a               
          Hearing (notice of intent to levy), dated October 5, 2000,                  
          proposing a levy with respect to petitioners’ unpaid tax                    
          liabilities totaling $19,366.69 for 1992 and $39,851.27 for 1993.           
          In response to this notice, petitioners submitted a timely Form             
          12153, Request for a Collection Due Process Hearing, dated                  
          October 18, 2000, raising an offer in compromise as an                      
          alternative to levy.                                                        
               Shortly after requesting their Appeals hearing, petitioners            
          submitted to respondent a Form 656, Offer in Compromise (offer in           
          compromise), signed October 22, 2000.  Petitioners also submitted           
          a Form 433-A, Collection Information Statement for Individuals,             
          listing a $520 “tithe to church” as a monthly necessary living              
          expense.                                                                    



               3 Until early 2001, Mr. Pixley was also employed by                    
          Cardiology Associates of Houston, Texas.                                    




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