Edward H. and Anne G. Harrell - Page 5

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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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