Arthur A. Lemann III and Roberta A. Lemann - Page 4

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               The record shows no further activity with respect to the               
          hearing until April 8, 2002, when a second Appeals officer                  
          assigned to conduct the hearing sent a letter requesting that               
          petitioners review and update their previously submitted Form               
          433-A and provide additional documents related to their financial           
          condition.  Petitioners submitted the requested information on              
          April 16, 2002.  On their revised Form 433-A, petitioners                   
          indicated they had net equity in their assets of approximately              
          $67,000 (up from $31,000), and monthly gross income of $7,715 per           
          month (up from $7,423).  Petitioners' monthly expenses remained             
               By letter dated April 19, 2002, the Appeals officer advised            
          petitioners that their proposed installment agreement of $1,500             
          per month was not acceptable because it would not result in                 
          payment of all amounts due within the applicable periods of                 
          limitation on collection.  The letter informed petitioners that             
          an offer-in-compromise might serve as an alternative to the                 
          proposed levy and explained that such an approach would require             
          petitioners to make a payment equal to the net realizable equity            
          in their assets, which might require borrowing against those                
               On April 22, 2002, petitioners submitted a Form 656, Offer             
          in Compromise, in which they offered to make a one-time payment             
          of $67,000 to compromise their aggregate unpaid tax liabilities             

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