Joseph G. Dostal - Page 8

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             Petitioner’s attorney repeats his contention that                        
             petitioner cannot part with the funds necessary to make                  
             full payment because those funds will be needed, after his               
             retirement, to satisfy his medical and living expenses and               
             to support him, his wife, and his children.  Petitioner’s                
             attorney states as follows:                                              

                  given Mr. Dostal’s age and retirement needs,                        
                  future and current medical and living costs,                        
                  and projected retirement needs, he is required                      
                  to contribute a certain amount to his retirement                    
                  accounts to insure a modest living standard for                     
                  himself, his wife, and children.                                    

             Petitioner’s attorney summarizes petitioner’s position as                

                  Considering Mr. Dostal’s age, his future                            
                  financial and health needs, his spouse and                          
                  children’s future financial needs, it is clear                      
                  that any and all savings, retirement savings                        
                  and the like, will be needed, and spent toward                      
                  their support, and the future support of their                      
                  children.  The amount of taxes owed, the Dostal’s                   
                  [sic] present and future financial needs,                           
                  Mr. Dostal’s few remaining years or months of                       
                  employment remaining [sic], and their family                        
                  support needs, warrant approval of this Offer                       
                  in Compromise.                                                      

                  Petitioner’s attorney emphasizes that petitioner                    
             had incurred unsecured debt in the aggregate amount of                   
             approximately $203,000 and had monthly medical expenses                  
             of approximately $1,000, consisting of medical insurance                 

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