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petitioners alleged that their income tax liabilities for tax
years 1991, 1992, and 1993 were discharged as a result of their
chapter 7 bankruptcy proceeding.
There followed an extended series of communications, some
among various IRS employees themselves, and others between some
of the same IRS employees and petitioners’ representative, Guy C.
Crowgey (Mr. Crowgey). These are summarized as follows.
Revenue Officer Carol Sewel (RO Sewel) spoke with Deborah
Stanley, an attorney in respondent’s counsel’s office, (RC
Stanley) for an interpretation of the meaning of the term “court-
ordered payments” as that term applied to the necessary living
expenses claimed by petitioners as part of the Request for an
Installment Agreement.
RO Sewel spoke with Mr. Crowgey regarding the advice she
received from RC Stanley. Mr. Crowgey disagreed with the
substance of that advice. Mr. Crowgey spoke with RC Stanley
regarding the necessary living expenses claimed by petitioners.
On February 1, 1999, Mr. Crowgey wrote to Chief of
Collection, Mark Rocawich, requesting that the Request for an
Installment Agreement be reassigned from RO Sewel’s group in
Virginia Beach.
On February 5, 1999, the Collection Division referred the
Offer in Compromise to Linda Hawkins, the Offer Coordinator for
respondent’s Examination Division in Richmond, Virginia.
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