D. Jean Bartelma and Dan F. Bartelma - Page 3

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          liabilities that flowed through to petitioners’ individual returns.         
               In January 1998, the IRS sent to petitioners 30-day letters            
          regarding the adjustments made with respect to the partnership’s            
          liabilities.  Petitioners, through their representative,                    
          Marvin D. Berger (Berger), filed protests to the IRS                        
          determination on or about February 3, 1998, and requested that              
          the examination findings be appealed to the IRS Appeals Office              
          (Appeals).  Their cases were assigned to an Appeals officer,                
          Eugene H. DeBoer (DeBoer), in August 1998.  DeBoer sent letters             
          dated August 13, 1998, to Berger informing him that petitioners’            
          cases had been referred to him for consideration.  After a                  
          conference with petitioners and after exchanging correspondence             
          for a number of months, DeBoer sent a letter dated December 21,             
          1999, to Berger requesting that petitioners sign a proposed                 
          agreement.  This letter stated that “By law, interest accrues               
          from the due date of the return.  In order to stop additional               
          interest from accruing, you may enclose full payment payable to             
          the United States Treasury.”  Petitioners had also been advised             
          during the examination and audit process that they could make an            
          advance payment of tax to stop the running of interest.                     
               On February 1, 2000, the IRS sent statutory notices of                 
          deficiency (notices) to petitioners.  The notice sent to Dan and            
          D. Jean Bartelma (Jean) determined a deficiency of $23,808.  The            

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