John G. Goettee, Jr. and Marian Goettee - Page 28

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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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