Craig F. and Lynn M. Rehberg - Page 6

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          Of Intent To Levy And Notice Of Your Right To A Hearing                     
          concerning petitioners’ unpaid liability.                                   
               On July 29, 2002, petitioners timely filed with respondent             
          Form 12153, Request for a Collection Due Process Hearing.                   
               On May 13, 2003, Mr. Rehberg attended an administrative                
          hearing conducted at respondent’s Appeals Office in Seattle,                
          Washington.  Throughout petitioners’ Appeals consideration, the             
          parties exchanged substantial correspondence concerning                     
          petitioners’ distressed financial situation and collection                  
               On August 28, 2003, the Appeals Office sent petitioners a              
          Notice of Determination Concerning Collection Action(s) Under               
          Sections 6320 and/or 6330 (notice of determination) concerning              
          petitioners’ unpaid liability.  In the notice of determination,             
          the Appeals Office stated that respondent’s determination to                
          proceed with collection by way of levy should be sustained.                 
               On October 1, 2003, petitioners filed a Petition for Lien or           
          Levy Action Under Code Section 6320(c) or 6330(d) challenging               
          respondent’s determination.10  In the petition, petitioners                 
               Liability is for capital gains taxes on our primary                    
               -Asking for relief under 1997 law for one time                         
               exclusion of capital gains tax for sale of residence.                  

               10  The petition was timely mailed to the Court on Sept. 26,           
          2003.  Secs. 6330(d), 7502(a).                                              

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