J. Jean Moore - Page 3

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          her probation, petitioner was ordered to pay $250,000 toward her            
          outstanding 1992 through 1995 Federal income taxes, penalties,              
          and interest.                                                               
               On her 1997 through 2001 individual Federal income tax                 
          returns, which she late filed on November 7, 2002, and on her               
          timely filed 2002 individual Federal income tax return,                     
          petitioner reported a cumulative total tax liability of                     
          approximately $1 million.  Petitioner made no payments to                   
          respondent with her filed tax returns, nor had petitioner made              
          any payments via withholding or estimates.                                  
               Respondent did not audit and did not otherwise dispute                 
          petitioner’s 1997 through 2002 Federal income taxes as reported             
          by petitioner on her tax returns.2                                          
               For 2003 and 2004, petitioner apparently has timely filed              
          her individual Federal income tax returns, and for purposes of              
          this collection action respondent has not questioned the tax                
          liabilities and tax payments reported thereon.                              
               On September 23, 2003, respondent filed a Federal tax lien             
          against petitioner relating to petitioner’s assessed and unpaid             
          1997 through 2002 cumulative total tax liability of approximately           
          $1 million, and on September 26, 2003, respondent mailed to                 

               2  Information relating to petitioner’s 1996 individual                
          Federal income tax return is not in the record.                             

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