Miguel Pagan, Jr. and Martha C. Pagan - Page 4

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          uled for March 16, 1994.  Petitioner canceled the March 16, 1994,           
          meeting.  It was rescheduled for March 28, 1994.  Petitioner                
          canceled the March 28, 1994, meeting but requested permission to            
          mail the necessary documents to the Appeals Officer.                        
               On April 19, 1994, the Appeals Officer telephoned                      
          petitioners to inquire as to the status of the expected records.            
          Petitioner again promised to mail the information to the Appeals            
          Officer.  On April 29, 1994, the Appeals Officer again called               
          petitioners to inform them that no records had, as yet, been                
          received.  Petitioner informed the Appeals Officer that she had             
          not yet sent the desired documents.  The Appeals Officer then               
          mailed petitioners a letter summarizing many phone calls and                
          canceled meetings that had occurred.  On May 4, 1994, the Appeals           
          Officer mailed petitioners a letter that informed petitioners               
          that their substantiation documentation had not been received and           
          included decision documents reflecting the amounts due as shown             
          on the statutory notice.  The Appeals Officer then attempted to             
          reach petitioners by phone on May 4 and 5, 1994.                            
               On May 16, 1994, respondent telephoned petitioner and                  
          informed her of the need to file a status report and the need for           
          the substantiation materials in order to proceed with settlement;           
          respondent suggested that a joint status report be filed.  On               
          May 17, 1994, respondent attempted to reach petitioners by phone            
          at home and at their places of employment.  On May 18, 1994,                






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