Anthony Edward and S.F. O'Connor - Page 3

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               This proceeding arises from a petition for judicial review             
          filed in response to a Notice of Determination Concerning                   
          Collection Action(s) Under Section 6320 and/or 6330 (notice of              
          determination) issued to petitioners on April 5, 2006.  Pursuant            
          to sections 6320(c) and 6330(d), petitioners seek review of                 
          respondent’s determination sustaining the filing of a notice of             
          Federal tax lien against them.  The issue for decision is whether           
          respondent abused his discretion in rejecting an offer-in-                  
          compromise (OIC) that petitioners submitted for the taxable years           
          2000 and 2001.                                                              
               The record consists of the declaration of respondent’s                 
          settlement officer, a copy of respondent’s administrative file,             
          and the testimony of petitioner Anthony O’Connor.  At the time              
          the petition was filed, petitioners resided in Citrus Springs,              
          Florida.  Petitioners have a daughter who was 9 years old at the            
          time of trial.                                                              
               Respondent made assessments against petitioners for the                
          taxable years 2000 and 2001 for tax and related interest.                   
          Respondent also assessed an accuracy-related penalty for the                
          taxable year 2000.  Respondent filed a notice of Federal tax lien           
          and sent petitioners a Notice of Federal Tax Lien Filing and Your           
          Right to a Hearing Under IRC 6320.                                          

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