Harvey L. Hoover - Page 4

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          of filing a notice of Federal tax lien; and (2) whether                     
          respondent’s Appeals officer abused his discretion in sustaining            
          the collection action of issuance of a notice of jeopardy levy.4            
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts, the first, second, third, and fourth              
          supplemental stipulations of facts, and the attached exhibits are           
          incorporated herein by this reference.  The stipulations of facts           
          include transcripts and exhibits from petitioner’s criminal                 
          prosecution, which commenced on March 16, 1998.  The stipulations           
          incorporate the trial testimony of the witnesses from the                   
          criminal prosecution as though it were given during the course of           
          the trial in this Court.                                                    
               The petition in docket No. 15557-99 was filed on September             
          28, 1999.  The petition in docket No. 4590-00L was filed on April           
          25, 2000.  When he filed the petitions in these cases, petitioner           
          was incarcerated in a Federal penitentiary in Elkton, Ohio.  Upon           
          release from prison in 2002, petitioner resided in Wabash,                  
               Petitioner married Judith Ann Mosier on or about June 28,              
          1959.  Michael Hoover and Tadd Hoover are two of the couple’s               
          children.  Petitioner and Ms. Mosier divorced on July 25, 1990.             

               4 The taxes involved in the collection action are the income           
          tax liabilities for 1989, 1990, 1991, and 1992 that are in issue            
          in docket No. 15557-99.                                                     

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