Robert A. and M. Faye Strang - Page 3

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          reviewing the relevant returns.  In early 1997, Agent Garner                
          included petitioners’ 1995 income tax return in the examination.            
          Respondent issued a 30-day letter to petitioners on June 10,                
          1997, for the taxable years 1993, 1994, and 1995, and Agent                 
          Garner held a closing conference with petitioner on the same day.           
          Agent Garner closed the case on July 28, 1997, after receiving a            
          protest letter from petitioners.                                            
               Petitioners’ case was assigned to IRS Appeals Officer Roger            
          Allen on August 28, 1997.  Officer Allen met with petitioner on             
          December 9, 1997, but he did not work on petitioners’ case                  
          between January 9, 1998, and June 9, 1998, because of his                   
          caseload and other priorities.  Officer Allen received                      
          petitioners’ offer of settlement on July 6, 1998, and respondent            
          received an executed settlement agreement from petitioners on               
          October 16, 1998.  Tax and interest were assessed on November 12,           
          1998, pursuant to the agreement.                                            
               Petitioners submitted a Claim for Refund and Request for               
          Abatement (Form 843) on February 10, 1999, for tax years 1993,              
          1994, and 1995.  On February 7, 2000, respondent mailed to                  
          petitioners a final determination disallowing petitioners’ claim            
          for abatement of interest under section 6404(e)(1).  Respondent             
          stated therein that he “did not find any errors or delays that              
          merit abatement of interest”.                                               

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