Anthony Edward and S.F. O'Connor - Page 4

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               Petitioners timely submitted a Form 12153, Request for a               
          Collection Due Process Hearing.  They also submitted an OIC in              
          which they made a cash offer of $9,500 to compromise their 2000             
          and 2001 tax liabilities.  The OIC was based on effective tax               
          administration.  Petitioners stated that Mr. O’Connor had been in           
          a serious car accident that resulted in 9 weeks of                          
          hospitalization, including 5 weeks spent in a coma, and rendered            
          him unable to work.                                                         
               Petitioners provided respondent with financial information             
          in support of the OIC.  Petitioners indicated they owned a                  
          residence with a fair market value of $85,000 that was subject to           
          a $55,225 mortgage.  Petitioners also indicated they owned a                
          building with a fair market value of $149,000 that was                      
          unencumbered.  Petitioners rented a portion of the building to an           
          unrelated party and used the remainder for Mr. O’Connor’s                   
          computer and television repair business.  After Mr. O’Connor was            
          injured, however, the repair business generated little or no                
               Petitioners’ case was assigned to a settlement officer, who            
          conducted an administrative hearing.  Petitioners did not seek to           
          challenge the underlying tax liabilities during the hearing or              
          offer collection alternatives aside from the OIC.                           
               After the hearing was concluded, respondent issued the                 
          notice of determination sustaining the lien filing and rejecting            

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