Joseph G. Dostal - Page 11

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             National Securities Corp., acct. for Teresa S. Fisher      $2,145.00     
             National Securities Corp., acct. for Joe Dostal139,580.70                  
             Piper Jaffray, acct. for Joe Dostal     3,484.70                         
             Piper Jaffray, retirement acct. for Joe G. Dostal34,541.63                   
             Piper Jaffray, acct. for Teresa S. Fisher        84.64                   

             In his letter of May 5, 2004, petitioner’s attorney, among               
             other things, disclosed to the Appeals officer that                      
             “Mr. Dostal has a tax liability for 2003, of roughly                     
             $70,000.00 and intends to pay this with funds on hand;                   
             namely, funds from his retirement account(s).”                           
                  At that time, petitioner had requested the first of                 
             two extensions to file his return for 2003.  Petitioner’s                
             return would not be filed until on or about October 14,                  
             2004, more than 5 months later.  As filed, the return                    
             reported total tax of $11,575 and Federal income tax                     
             withholding of $6,415, leaving an amount due of $5,160.                  
             See appendix.  The record does not explain why petitioner’s              
             attorney advised the Appeals officer that petitioner’s tax               
             liability for 2003 was $70,000.                                          
                  Shortly thereafter, during a telephone conference,                  
             the Appeals officer advised petitioner’s attorney that she               
             could not consider petitioner’s offer-in-compromise, as a                
             collection alternative because petitioner had incurred                   
             unpaid tax liabilities for tax year 2003.  The Appeals                   
             officer gave petitioner’s attorney a short time to request               

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