Theodore C. and Denise M. Schwartz - Page 3

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                         2000                       20,154.68                         
                         2001                       37,315.70                         
                         2002                       30,729.60                         
                         2003                       23,566.81                         
                       Total                       153,721.43                         
          On July 5, 2005, petitioners, through their authorized                      
          representative, executed and submitted a Form 12153, Request for            
          a Collection Due Process Hearing.  Attached was a letter, which             
          stated in relevant part:                                                    
               Levies placed on bank accounts would cause undue                       
               hardship.  The taxpayer has made Estimated Tax Deposits                
               for 2005.  The taxpayer is completing Financial Form                   
               433-A.  This will assist in determining repayment                      
               ability.  It would also result in the inability to                     
               pursue all avenues to resolve this liability and                       
               prevent the repayment of the outstanding liability owed                
               to the Internal Revenue Service.                                       
               In light of the taxpayer’s current situation, it is                    
               requested that no enforcement action take place against                
               Theodore and Denise Schwartz.  The taxpayer is                         
               interested in resolving this liability as quickly and                  
               efficiently as possible.                                               
               On September 15, 2005, respondent sent petitioners a letter            
          acknowledging receipt of petitioners’ case in respondent’s San              
          Jose Appeals Office.  On September 23, 2005, Appeals Officer                
          Colleen Cahill (Ms. Cahill) sent petitioners a letter inviting              
          them to contact her to schedule a section 6330 hearing and to               
          request that petitioners provide a completed Form 433-A,                    
          Collection Information Statement for Wage Earners and Self-                 
          Employed Individuals, a signed 2004 tax return, and proof of                

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