Rudolph Harris, Sr., and Verline Harris - Page 2

                                        - 2 -                                         
                                  FINDINGS OF FACT                                    
               At the time they filed the petition, Rudolph Harris, Sr.,              
          and Verline Harris resided in Tampa, Florida.  Mr. and Mrs.                 
          Harris filed Federal income tax returns reporting as follows:2              

                                             Withholding                              
                                            plus payments                             
                Year             Tax         with return        Tax Due               
                1995           $3,461          $1,761           $1,700                
                1996            2,262           1,214            1,048                
                1997            2,591           518              2,073                
                1998            1,787           981              806                  
                1999            3,555           2,761            794                  
               According to Internal Revenue Service (IRS) transcripts of             
          account, on or about October 29, 2001, the IRS received an offer-           
          in-compromise (OIC) from Mr. and Mrs. Harris to settle their                
          1995, 1996, 1997, 1998, and 1999 tax liabilities (first OIC).               
          The boxes for “Doubt as to Collectibility” and “Effective Tax               
          Administration” are marked on the first OIC.  On March 29, 2002,            
          the IRS rejected the first OIC.                                             
               On or about July 26, 2002, Mr. and Mrs. Harris submitted               
          another OIC to settle their 1995, 1996, 1997, 1998, and 1999 tax            
          liabilities (second OIC).  The boxes for “Doubt as to                       
          Collectibility” and “Effective Tax Administration” are marked on            
          the second OIC.  At this time, Mr. and Mrs. Harris were 71 years            


               2  All amounts are rounded to the nearest dollar.                      




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