Zane D. and Debbie L. Worman - Page 5




                                        - 4 -                                         
                         Internal Revenue Service                                     
                         DP S-661A                                                    
                         P.O. Box 1064                                                
                         Bensalem, PA 19020                                           
               You must request your hearing by 03/20/2006.                           
               We’ll issue a Certificate of Release of the Federal Tax                
               Lien within 30 days after you pay the full amount owed.                
               Petitioners received the lien notice.  However, they did not           
          file with respondent a Form 12153, Request for a Collection Due             
          Process Hearing, or a written equivalent.  Rather, petitioners              
          filed with this Court on March 3, 2006, a petition disagreeing              
          “with the determination contained in the notice issued by the               
          Internal Revenue Service for the year(s) or period(s) 1995, 1998,           
          2002, [and] 2003, as set forth in such notice dated 2/16/2006”.3            
          As an exhibit to the petition, petitioners attached a copy of the           
          lien notice, as well as a copy of the notice of Federal tax lien            
          filed with the Campbell County Clerk in Gillette, Wyoming.                  
               By notice dated January 19, 2007, this case was calendared             
          for trial at the Court’s trial session scheduled for June 22,               
          2007, in Cheyenne, Wyoming.                                                 
               On February 26, 2007, respondent filed a Certificate of                
          Release of Federal Tax Lien with the Campbell County Clerk in               
          Gillette, Wyoming.  The certificate of release recites that                 
          petitioners have satisfied the taxes and all statutory additions            

               3  The petition arrived at the Court by Priority Mail in an            
          envelope bearing a U.S. Postal Service postmark dated Feb. 27,              
          2006.                                                                       






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