John E. Hunter, II and Alma E. Hunter - Page 3

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          October 8, 2004.  The case at docket No. 14984-05L arises from a            
          petition filed in response to a Determination Letter Concerning             
          Collection Action(s) Under Section 6320 and/or 6330 (notice of              
          determination) issued on August 2, 2005.  Mrs. Hunter is not a              
          party to the case at docket No. 14984-05L.                                  
               The first issue for decision is whether John E. Hunter, II,            
          and Alma E. Hunter (the Hunters) are liable for $976 of                     
          alternative minimum tax (AMT) for the taxable year 2002.  The               
          remaining issues for decision are whether the Hunters are                   
          entitled to a credit against their tax liability for 2002 and               
          whether Mr. Hunter was denied an adequate opportunity for an                
          administrative hearing regarding a notice of Federal tax lien               
          filing and a proposed levy action against him.                              
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated, and the stipulated             
          facts are incorporated as our findings by this reference.  The              
          record consists of the stipulation of facts with attached                   
          exhibits for each case, additional exhibits introduced at trial,            
          and the testimony of Mr. Hunter.  The Hunters are married and               
          resided in Ann Arbor, Michigan, at all relevant times.                      
               Each case before us involves the taxable year 2002.  Because           
          a primary source of dispute concerns the taxable year 2001,                 
          however, we begin by describing the facts relevant to that year.            

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