Raymond M. and Joy D. Jean - Page 5




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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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