Johnny and M. Suzan Black - Page 5

          with a net realizable equity totaling $170,000.  Including other            
          assets, petitioners’ net realizable equity was reflected by the             
          IRS as $239,567.  The IRS determined that petitioners could pay             
          their tax liabilities in full.                                              
          B. Notice of Federal Tax Lien                                               
               A notice of Federal tax lien was filed on October 21, 2003.            
          On October 24, 2003, respondent issued to petitioners a Notice of           
          Federal Tax Lien Filing and Your Right to a Hearing Under IRC               
          6320.  Petitioners timely requested a hearing on Form 12153,                
          Request for Collection Due Process Hearing (Form 12153).                    
          Petitioners explained in the Form 12153 that “Prior to submitting           
          an offer in compromise, we were making scheduled payments for               
          several years.  If there are no other options we would like to              
          continue making payments without the lien being placed on the               
               Petitioners had a hearing with the IRS Office of Appeals.              
          After some correspondence between petitioners and the Office of             
          Appeals, the notice of determination was issued on August 6,                
          2004.  The Appeals officer indicated:                                       
               Appeals considered the $5,000 rejected offer to                        
               compromise approximately $27,000 of liabilities.  While                
               your net spendable income was about $1,700 per month it                
               was the equity in your personal residence that kept the                
               offer from being accepted.                                             
                         *    *    *    *    *    *    *                              
               It is not clearly known what your position is although                 
               based upon conversations it appeared they * * *                        

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