David and Monika Zisskind - Page 4

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          information provided by petitioners unsatisfactory and returned             
          the offer-in-compromise forms to petitioners on April 27, 2004.             
               On April 29, 2004, respondent sent petitioners a Notice of             
          Federal Tax Lien and Your Right to a Hearing Under IRC 6320                 
          (notice of Federal tax lien) for their outstanding tax liability            
          for 1999.  At the time respondent issued the notice of Federal              
          tax lien, petitioners owed $29,414, including penalties and                 
               On May 18, 2004, petitioners submitted to respondent a Form            
          12153, Request for a Collection Due Process Hearing (request for            
          a section 6330 hearing).  Petitioners requested that an offer-in-           
          compromise or an installment agreement be entered into.  However,           
          petitioners did not provide a Form 656, a Form 433-A, or an                 
          installment agreement request.2                                             
               On June 17, 2004, Settlement Officer Maria Russo (Ms. Russo)           
          of respondent’s Boston Appeals Office was assigned to                       
          petitioners’ case.  On September 28, 2004, Timothy J. Burke (Mr.            
          Burke), petitioners’ attorney, telephoned Ms. Russo to discuss              
          petitioners’ request for a section 6330 hearing.  On October 21,            

               2  At various times during their sec. 6330 hearing and                 
          afterwards, petitioners requested an offer-in-compromise or an              
          installment agreement.  In the notice of determination,                     
          respondent determined that petitioners abandoned their request              
          for an offer-in-compromise and did not provide adequate financial           
          information so that an installment agreement could be considered.           
          Petitioners do not dispute this determination in their petition             
          or on brief, and we do not discuss the offer-in-compromise and              
          the installment agreement further.                                          

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