Edward H. and Anne G. Harrell - Page 6

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               On May 24, 1999, Revenue Agent R. Wygand, the revenue agent            
          assigned to review the Offer in Compromise, spoke with Mr.                  
          Crowgey, who requested that the Offer in Compromise be reviewed             
          by respondent’s counsel’s office.                                           
               On June 16, 1999, a memorandum written by RC Stanley                   
          addressing the merits of the Offer in Compromise was sent to                
          Group Manager Bill Stevens.                                                 
               On July 12, 1999, respondent issued a letter to petitioners            
          notifying them of their right to appeal respondent’s                        
          determination that the Offer in Compromise should be rejected.              
               On August 5, 1999, petitioners filed a protest of the                  
          rejection of the Offer in Compromise.                                       
               Appeals Officer Barbara Petrohovich (AO Petrohovich) was               
          assigned to review the Offer in Compromise.  AO Petrohovich was             
          also assigned to conduct a hearing pursuant to section 6330                 
          regarding certain of petitioners’ tax years not here at issue.              
               Between August 30, 1999, and January 3, 2000, AO Petrohovich           
          discussed the dischargeability of taxes in petitioners’                     
          bankruptcy proceeding with RC Stanley approximately three times.            
          AO Petrohovich initiated the communications with RC Stanley, and            
          all the communications occurred in RC Stanley’s office, which was           
          in the same suite of offices as the office of AO Petrohovich                

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