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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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