Edward H. and Anne G. Harrell - Page 8

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          the issuance of this letter, AO Petrohovich corresponded with               
          Appeals Chief Gretes regarding the contents of the June 16, 1999,           
          memorandum written by RC Stanley.                                           
               On September 1, 2000, Appeals Chief Gretes agreed to the               
          rejection of the Offer in Compromise.                                       
               On September 5, 2000, AO Petrohovich sent a letter to                  
          petitioners, with a copy to Mr. Crowgey, rejecting the Offer in             
          Compromise.  The parties stipulated that petitioners did not                
          appeal this determination directly to this Court, or to any other           
          court, since no such appeal was allowed for the IRS’s rejection             
          of their Offer in Compromise.                                               
               On December 25, 2000, the IRS issued to petitioners a “Final           
          Notice - Notice of Intent to Levy” (Notice of Intent to Levy)               
          with regard to income tax liabilities for tax years 1991, 1992,             
          1993, and 1999.                                                             
               On January 23, 2001, petitioners requested a hearing                   
          pursuant to section 6330 with respect to the Notice of Intent to            
               On January 25, 2001, Mr. Crowgey sent a letter to Appeals              
          Chief Gretes, with a copy to Daniel Black, National Chief,                  
          Appeals, requesting that “his entire office recuse itself from              
          this case at this time and this case file either be referred to             
          another regional office or to the national office in Washington,            

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