Kent E. Hovind - Page 2

                                         -2-                                          
               Unless otherwise indicated, all section references are to              
          the Internal Revenue Code in effect for the years in issue, and             
          all Rule references are to the Tax Court Rules of Practice and              
          Procedure.                                                                  
               For purposes of the instant cross-motions for summary                  
          judgment, and the respective objections thereto, the record                 
          consists primarily of documents set forth in respondent’s                   
          administrative file, the pleadings filed herein, and the parties’           
          cross-motions for summary judgment and attachments thereto.                 

                                     Background                                       
               Respondent seeks to levy on petitioner’s property in                   
          connection with assessed and outstanding 1995, 1996, and 1997               
          Federal income taxes and additions to tax and interest in the               
          cumulative total amount of $520,099.                                        
               Petitioner apparently has a college degree from the                    
          Midwestern Baptist College located in Pontiac, Michigan, with a             
          major in religious education.  Petitioner has established a                 
          purported religious ministry under the name of Creation Science             
          Evangelism, based in Pensacola, Florida.                                    
               Allegedly as part of his ministry, petitioner produces and             
          sells books and recordings and travels extensively throughout the           
          United States and occasionally in other countries giving                    
          speeches.  Petitioner also hosts a daily radio talk show and has            
          established Dinosaur Adventure Land, which is described as a                





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Last modified: May 25, 2011