Irving and Elaine Steinberg - Page 3

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               Beginning September 9, 2004, petitioners, petitioners’                 
          attorney, and respondent held a series of phone calls and written           
          correspondence relating to petitioners’ Appeals Office hearing.             
          Some financial information was submitted by petitioners, and                
          respondent’s Appeals officer reviewed that material and asked               
          petitioners for additional information.                                     
               Petitioners submitted some additional financial information            
          to respondent’s Appeals Office, but certain financial information           
          that had been requested by respondent’s Appeals officer was not             
          provided by petitioners.  For example, petitioners never                    
          submitted documents requested by respondent’s Appeals officer               
          that would have established the fact of payment of petitioners’             
          medical and drug expenses.                                                  
               Based on the financial information petitioners submitted,              
          respondent’s Appeals officer determined that petitioners had                
          significantly more discretionary monthly income, equity in                  
          assets, and realizable collection potential (RCP) than                      
          petitioners would acknowledge.  The figures petitioners and                 
          respondent’s Appeals officer respectively calculated are set                
          forth below:                                                                

                                                Petitioners Respondent                
                Discretionary Monthly Income    $      0      $  2,937                
                Equity in Assets                82,853        319,535                 
                RCP                             127,087       460,511                 






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