Joseph G. Dostal - Page 13

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                  During our conference, we advised that you did                      
                  not qualify for an ETA offer [an offer in                           
                  compromise based upon Effective Tax Administra-                     
                  tion] because you had not demonstrated that you                     
                  had an undue hardship as defined under the Code                     
                  of Federal Regulations Section 6343-1.  We                          
                  advised that you had the ability to full pay                        
                  your tax liability and we proposed that your                        
                  representative ask you to consider an installment                   
                  agreement and/or liquidation of your retirement                     
                  accounts in order to satisfy the tax liability.                     
                  We asked your representative to provide us with                     
                  some additional documentation which included a                      
                  draft of your Form 1040 for 2003.  We advised                       
                  that you could not owe a balance due if you still                   
                  wished to pursue an offer.                                          
                  On May 10, 2004 we received some additional                         
                  documentation from your representative.  In his                     
                  cover letter, your representative advised us that                   
                  you were going to owe $70,000.00 for the tax year                   
                  2003 and intended to pay the amount due with                        
                  funds from your retirement accounts.                                
                  On May 19, 2004 and May 25, 2004, we held                           
                  telephone conferences with your representative                      
                  and advised that we could no longer consider an                     
                  offer because you had not complied with your                        
                  payment requirements and had incurred another                       
                  liability while your offer was being considered.                    
                  We noted that the current balance in your                           
                  retirement accounts was approximately                               
                  $178,000.00.  Your representative asked if you                      
                  could enter into an installment agreement.  We                      
                  advised that we would consider an installment                       
                  agreement if you paid your 2003 tax year in full,                   
                  made a substantial payment towards your tax                         
                  liability for 2000 and 2001, and provided some                      
                  missing documentation in order to determine the                     
                  precise amount of your monthly installment                          
                  payment.  *  *  *                                                   
                       Your representative advised that he would                      
                  discuss the proposal with you.  We asked to be                      
                  contacted by June 1, 2001 [sic].  On May 26, 2004                   
                  we sent and faxed a letter to your representative                   
                  outlining the terms under which we could consider                   
                  an installment agreement.  On June 1, 2004, your                    

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