Ronald W. Oman - Page 4

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          past non-compliance”, and respondent’s “analysis of * * *                   
          [petitioner’s] current finances reveals that it will be highly              
          unlikely * * * [petitioner] will be able to remain in compliance            
          during the offer terms.”  Therefore, respondent concluded “it               
          would not be in the best interest of the government”.  In the               
          “REJECTION NARRATIVE” prepared in connection with the letter                
          informing petitioner of the rejection, dated August 10, 2004,               
          respondent noted that petitioner’s “reasonable collection                   
          potential” was zero.                                                        
               Shortly before rejecting the offer-in-compromise,                      
          respondent, on July 22, 2004, filed a Notice of Federal Tax Lien            
          in Seminole County, Florida, with respect to petitioner’s 1990,             
          1993, 1994, 1996, 1997, 1999, 2000, and 2001, income tax                    
          liabilities.  Respondent then, on July 23, 2004, issued to                  
          petitioner a corresponding Notice of Federal Tax Lien Filing and            
          Your Right to a Hearing Under IRC 6320 for the taxable years                
          1990, 1993, 1994, 2000, and 2001.2  In response, petitioner                 

               2Taxable years 1996, 1997, and 1999, were not covered by               
          this notice because respondent had previously issued, on October            
          25, 2000, a Notice of Federal Tax Lien Filing and Your Right to a           
          Hearing under IRC 6320 for these years and petitioner had not               
          timely requested a hearing in response to that notice.                      
          Respondent had also previously issued, on January 25, 1999, a               
          Final Notice of Intent to Levy and Notice of your Right to a                
          Hearing for taxable years 1993 and 1994, and petitioner had also            
          not timely requested a hearing in response to that notice.                  
          Because petitioner’s requests for a hearing on the proposed levy            
          for 1993 and 1994, and the filed lien as to 1996, 1997, and 1999,           
          were filed late, petitioner was afforded an equivalent                      
                                                             (continued...)           




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