Raymond M. and Joy D. Jean - Page 4




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               On August 14, 1996, Agent Ruiz issued a 30-day letter to               
          petitioners in which she proposed changes to their 1993 return.             
          On August 27, 1996, petitioners sent a letter to respondent                 
          agreeing and disagreeing, in part, with Agent Ruiz’s proposed               
          changes.  Respondent interpreted petitioners’ letter as a request           
          that their case be transferred to the Appeals Office.  On October           
          22, 1996, Appeals Officer Danny Raley (Appeals Officer Raley)               
          sent petitioners a letter requesting a conference to negotiate a            
          resolution of the matters with which petitioners disagreed.  On             
          numerous occasions, Appeals Officer Raley requested documentation           
          supporting petitioners’ claimed NOL.4  Over the course of the               
          next year, respondent and petitioners resolved several issues               
          from the audit of petitioners’ 1993 return.                                 
               On October 7, 1997, Appeals Officer Raley informed                     
          petitioners that he was returning their case to the examination             
          branch of the Internal Revenue Service to review petitioners’               
          documentation regarding the NOL.  On October 23, 1997, Agent Ruiz           
          contacted petitioners to schedule a conference to discuss the               
          NOL.  Petitioners informed Agent Ruiz that they did not wish to             
          meet with her and wanted their case assigned to a different                 
          agent.                                                                      


               4Appeals Officer Raley sent letters to petitioners on Nov.             
          12, 1996, June 2, 1997, July 9, 1997, and Sept. 5, 1997,                    
          describing the specific documents petitioners needed to produce             
          to substantiate their claim to the NOL.                                     






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