Gary and Johnean Hansen - Page 4

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          liability to promote effective tax administration.  Petitioners             
          contended that Appeals should accept their offer as a matter of             
          equity and public policy.  Petitioners stated that it took a long           
          time to resolve the Hoyt partnership cases and noted that Hoyt              
          had been convicted on the criminal charges.  The second issue               
          concerned an interest abatement case under section 6404(e) that             
          petitioners then had pending in this Court at docket No.                    
          18896-03.  That case related to 1989, the year at issue here, and           
          petitioners claimed that the proposed levy should be rejected               
          because the case was pending.  On April 28, 2005, the Court                 
          entered a decision in that case stating that the parties agreed             
          that petitioners were not entitled for 1989 to an abatement of              
          interest under section 6404.  That decision is now final.                   
               On February 15, 2005, petitioners tendered to Cochran on               
          Form 656, Offer in Compromise, a written offer to pay $90,258 to            
          compromise their estimated $260,143 liability.  The offer was               
          limited to a claim of effective tax administration because                  
          petitioners had sufficient assets to pay their tax liability in             
          full.  Petitioners supplemented their offer with a completed Form           
          433-A, Collection Information Statement for Wage Earners and                
          Self-Employed Individuals, four letters totaling approximately 65           
          pages, and volumes of documents.  The Form 433-A reported that              

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