Russel S. Bankson - Page 5

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               Petitioner and the Appeals officer exchanged additional                
          correspondence.  At some point during that time, respondent                 
          learned that petitioner was president of an active California               
          corporation (the corporation).  This information is not listed in           
          the OIC or in petitioner’s letters to the Appeals officer.                  
          Respondent sent petitioner a letter in August 2004 again                    
          requesting his employment history, as well as “Financial and                
          other records with respect to any related corporations in which             
          you were an officer or shareholder.”                                        
               Petitioner claims he did not receive respondent’s August               
          2004 letter.  He acknowledges, however, that he did not provide             
          respondent with certain financial information, including                    
          information about the corporation, verification of Ms. Bernd’s              
          income, and a breakdown of the respective contributions toward              
          living expenses that he and Ms. Bernd made.  He also concedes his           
          OIC does not list any constructive income in the form of reduced            
          rent that he received from Ms. Bernd in exchange for performing             
          services for her.                                                           
               In November 2004, respondent issued petitioner a notice of             
          determination sustaining the filing of the notice of Federal tax            
          lien.  The notice of determination states:  (1) Petitioner failed           
          to provide adequate financial information, and (2) petitioner has           









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