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On November 6, 1997, petitioners’ case was assigned to
Revenue Agent Ed Clarke (Agent Clarke). On December 10, 1997,
Agent Clarke mailed a letter to petitioners requesting a
conference. On January 21, 1998, Agent Clarke met with
petitioners and received and copied several documents. On August
6, 1998, Agent Clarke left a telephone message for petitioners
asking that they return his phone call to schedule an appointment
with him. On September 1, 1998, Agent Clarke spoke with
petitioners and scheduled a meeting for September 3, 1998. Due
to Agent Clarke’s hospitalization, his group manager telephoned
petitioners and canceled Agent Clarke’s September 3, 1998,
conference with petitioners. Agent Clarke died on October 5,
1998.
On September 17, 1998, petitioners’ case was reassigned to
Revenue Agent Vickie McIntosh (Agent McIntosh). On September 29,
1998, Agent McIntosh received petitioners’ audit files. On
October 8, 1998, Agent McIntosh reviewed petitioners’ case. On
October 15, 1998, Agent McIntosh scheduled a conference with
petitioners for October 20, 1998. Petitioners subsequently
canceled the conference, which was rescheduled for October 22,
1998. On October 22, 1998, Agent McIntosh met with petitioner
Raymond Jean to discuss the NOL. On October 26, 1998, Agent
McIntosh met with her group manager, Elizabeth Laverty (Manager
Laverty), and spoke on the telephone with Appeals Officer Raley
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Last modified: May 25, 2011