Homer W. and Nancy L. Winans - Page 2

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                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               COLVIN, Judge:  Respondent sent Notices of Determination               
          Concerning Collection Action(s) Under Section 63202 (Lien) and/or           
          6330 (Levy) to petitioners in which respondent determined that it           
          was appropriate to file liens with respect to petitioners’ unpaid           
          income taxes for 1996-2001 and that respondent may proceed with             
          proposed levies for the years 1999-2001.                                    
               We sustain respondent’s determinations to proceed with                 
          collection of petitioners’ income tax liabilities for 1996-2001.            
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          A.   Petitioners                                                            
               Petitioners lived in Palm Coast, Florida, when the petitions           
          were filed.  During the years in issue through the time of trial,           
          Homer W. Winans (petitioner) worked as a consultant to hospitals            
          and petitioner Nancy L. Winans (Mrs. Winans) worked as a nurse.             
          On a date not stated in the record, petitioner filed with his               
          employer a Form W-4, Employee Withholding Allowance Certificate,            
          in which he claimed that he was exempt from Federal income tax              

               2  Unless otherwise provided, section references are to the            
          Internal Revenue Code as amended and in effect for the years in             

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