Francis A. Morlino - Page 4

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               On August 18, 2003, Mr. Burke (but not petitioner) met with            
          Mr. O’Shea.  Mr. Burke provided Mr. O’Shea with some, but not               
          all, of the information requested on the questionnaire.  He did             
          not submit the offer form.  Mr. O’Shea again extended the time              
          for completion of the questionnaire and submission of the offer             
          form, until September 2, 2003, and he informed Mr. Burke that no            
          further extension of time would be granted.                                 
               Petitioner did not submit the missing information or the               
          offer form to Mr. O’Shea by September 2, 2003, nor did petitioner           
          or Mr. Burke contact Mr. O’Shea between August 18 and September             
          2, 2003.                                                                    
               On September 10, 2003, Mr. O’Shea determined that collection           
          by levy of the unpaid tax should proceed.  In part, Mr. O’Shea              
          based his determination on the fact that petitioner had failed to           
          submit information necessary for an offer in compromise.  In                
          making his determination, Mr. O’Shea balanced the need for the              
          efficient collection of taxes with the concern that any                     
          collection action be no more intrusive than necessary.  He                  
          verified that the requirements of applicable laws and                       
          administrative procedures had been met.                                     
               Petitioner was notified of Mr. O’Shea’s determination by a             
          Notice Of Determination Concerning Collection Action(s) Under               
          Section 6320 and/or 6330 dated October 2, 2003.                             

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