Fletcher H. Hyler - Page 8

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          The Office of the Taxpayer Advocate also requested suspension of            
          collection activities during the consideration of petitioner’s              
          administrative claim, and the IRS did not undertake collection              
          activities while petitioner’s claim was pending.                            
               In the Seattle Appeals Office, petitioner’s claim was                  
          assigned for review to Special Procedures Advisor Jill Pace                 
          (Pace), who received it on August 6, 1999.  On August 11, 1999,             
          Pace sent to petitioner a form letter regarding the possibility             
          of third-party contacts; her letter was sent to the Portola                 
          Valley address that was on petitioner’s damages claim.  Pace did            
          not check IRS records to determine an alternate address for                 
          petitioner, and she was unaware that the address used by                    
          petitioner on the administrative claim was a new address.  During           
          her review of the administrative claim, Pace met with petitioner            
          and Stone.  Neither petitioner nor Stone informed Pace of                   
          petitioner’s change of address the previous November.  Petitioner           
          did, however, provide a Form 2848, Power of Attorney and                    
          Declaration of Representative, appointing Stone as his                      
          representative for multiple income tax periods including 1993,              
          1995, and 1997.                                                             
               On December 28, 1999, the holder of a deed of trust on                 
          petitioner’s residence commenced a nonjudicial foreclosure                  
          proceeding with the filing of a Notice of Default and Election to           

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