Brian and Tina Nicklaus - Page 5

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               Duncan reviewed respondent’s administrative records for                
          petitioners and all documents submitted by petitioners.  Duncan             
          considered petitioners’ arguments and concluded that petitioners            
          had not shown that there were any irregularities in assessment              
          procedures for the years in issue.                                          
               Respondent sent petitioners a Notice of Determination with             
          respect to the levy concerning their income tax liability for               
          1993 and 1994 on April 15, 2004.  Respondent sent a Notice of               
          Determination to petitioner with respect to the levy concerning             
          income tax he owed for 1995-2000 on April 15, 2004.  Petitioners            
          timely filed a petition in this Court.                                      
               On Forms 4340 for 1995 and 1996, Tina Nicklaus’s Social                
          Security number is partially incorrect and petitioner’s first               
          name is misspelled.                                                         
          A.   Contentions of the Parties and Background                              
               Petitioners contend that respondent’s transcripts show that            
          respondent did not follow proper assessment procedures and that             
          this Court lacked jurisdiction in their prior case before this              
          Court and in this case.  Petitioners ask that we vacate the                 
          decision in their prior case and that we remand this case to                

               1 Petitioners do not contend that sec. 7491(a) applies in              
          this case and have not established that they met the requirements           
          of sec. 7491(a)(2).                                                         

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