Edward H. and Anne G. Harrell - Page 7

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          during the entire time that AO Petrohovich was assigned to review           
          petitioners’ protest of the IRS’s rejection of the Offer in                 
               On December 15, 1999, AO Petrohovich held a conference with            
          Mr. Crowgey.  She informed Mr. Crowgey that she disagreed with              
          him regarding the dischargeability of petitioners’ income taxes             
          for tax years 1991, 1992, and 1993.                                         
               AO Petrohovich determined that she did not see substantial             
          hazards with regard to respondent’s position rejecting the Offer            
          in Compromise.  She came to this conclusion based on a review of            
          RC Stanley’s June 16, 1999, memorandum to Group Manager Stevens             
          that was contained in the collection file, the discussions with             
          RC Stanley regarding the substance of that memorandum, and her              
          own review of the court cases referenced by Mr. Crowgey.                    
               On January 6, 2000, Mr. Crowgey contacted Appeals Chief                
          George Gretes with regard to the handling of petitioners’ case.             
          Mr. Crowgey told Appeals Chief Gretes that it was his belief that           
          RC Stanley was an advocate for the Collection Division and that             
          he wanted someone else in respondent’s counsel’s office to review           
          this matter.                                                                
               On February 24, 2000, Appeals Chief Gretes sent a letter to            
          Mr. Crowgey that had been reviewed by AO Petrohovich.  Prior to             

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