Juanita and Emmanuel Kendricks - Page 6

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          filed a motion to determine the secured status of the IRS’s                 
          claim.  On December 16, 1996, the bankruptcy court granted                  
          petitioners’ motion to convert the bankruptcy case from a case              
          under Chapter 13 of the Bankruptcy Code to a case under Chapter             
          11 of the Bankruptcy Code, 11 U.S.C. ch. 11 (“Reorganization”).             
          Between December 1996 and November 1997, petitioners and the IRS            
          (the bankruptcy parties) engaged in discovery regarding                     
          petitioners’ objection to the IRS’s proof of claim, and, on                 
          November 10, 1997, the bankruptcy court entered an order setting            
          petitioners’ objection for trial on February 11, 1998.  On                  
          February 3, 1998, the bankruptcy court entered an order                     
          continuing the trial until April 13, 1998.  On March 31, 1998,              
          the bankruptcy parties filed a stipulation of dismissal,                    
          dismissing without prejudice both petitioners’ objection to the             
          IRS’s proof of claim and petitioners’ motion to determine secured           
          status.  On June 5, 2000, the bankruptcy case was dismissed upon            
          motion of the IRS when petitioners did not object.                          
          Notices of Intent To Levy and Right to Hearing                              
               By letter dated October 24, 2001, respondent sent Mrs.                 
          Kendricks a notice of intent to levy and a notice of her right to           
          a hearing under section 6330 (a collection due process hearing)             
          with respect to her 1982, 1983, and 1984 tax years, claiming                
          unpaid taxes, penalties, and interest for those years totaling              

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