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referred to as the Baltimore office), wrote to petitioners about
their appeal.
On April 10, 1996, Rowland wrote to petitioners from the
Cincinnati office in response to the letters from petitioners’
Congressman and both of their Senators. Her letter was
essentially consistent with respondent’s February 5 letter that
denied petitioners’ abatement requests in full.
On April 24, 1996, Becker traveled from Cincinnati to
petitioners’ residence in New Windsor, Maryland, to discuss their
interest liability. Becker gave to petitioners a Form 656 (Offer
in Compromise).
On April 29, 1996, Becker wrote to petitioners, in pertinent
part, as follows:
I have also spoken with people from the offices of
Congressman Roscoe B. Bartlett, Senator Barbara A. Mikulski
and Senator Paul S. Sarbanes. In each case, I have
explained your situation and pointed out that the interest
liability is fixed by statute.
It appears that the only avenue available to you at this
time is to prepare the necessary information and forms to
submit an Offer in Compromise to the Collection Division.
This can be done through the Internal Revenue Office in
Frederick or through the Baltimore Office.
On May 29, 1996, petitioners submitted a Form 656 in which
they offered respondent $40,000 to settle their interest
liability for 1978, 1979, 1981, 1982. Petitioners enclosed a
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