Joe Nathan Wright and Lola H. Wright - Page 7

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          their fourth offer in compromise by facsimile letter, only to               
          inform them several months later that such offer was not in                 
          proper form and therefore could not be considered, (5) took 6               
          months to deliver copies of requested transcripts of account,               
          (6) failed to provide petitioners a copy of their “master file”,            
          as requested in their fourth offer in compromise, (7) did not               
          accept petitioners’ proposal for an installment agreement, which            
          called for a monthly payment based on petitioners’ excess monthly           
          income, as previously determined by IRS personnel, (8) failed to            
          respond to petitioners’ 1997 letter requesting abatement of                 
          additions to tax, (9) failed to grant petitioners a requested               
          Appeals conference following the rejection of their fifth offer             
          in compromise, and (10) ignored petitioners’ requests for copies            
          of their transcripts of account and an Appeals conference                   
          following the rejection of their 1998 request for abatement of              
          interest and additions to tax.                                              
          III.  Analysis                                                              
               A.  Allegations 8-10                                                   
               We begin with petitioners’ allegations numbered 8, 9, and 10           
          above.  Petitioners did not raise any of those allegations in               
          their request for interest abatement; indeed, allegations 9 and             
          10 involve acts and omissions that could not have predated                  
          petitioners’ filing of that request.  Furthermore, the record is            
          devoid of any evidence that petitioners subsequently advised                






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