D. Jean Bartelma and Dan F. Bartelma - Page 4

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          notice sent to James and Cynthia C. Bartelma (Cynthia) determined           
          a deficiency of $27,457.  These notices stated that, if                     
          petitioners did not agree with the deficiency but wished to stop            
          the running of interest, they should make a cash bond and mail it           
          to the Appeals officer.  Dan and Jean filed their petition with             
          the Court on March 13, 2000, and James and Cynthia filed their              
          petition with the Court on March 3, 2000.  They did not make a              
          cash bond to stop the running of interest.  Those cases were                
          consolidated and settled, and decisions were entered on                     
          October 26, 2000.  The decisions resulted in deficiencies of                
          $10,760 against Dan and Jean and $14,396 against James and                  
          Cynthia.  Additionally, the decisions stated that “interest will            
          be assessed as provided by law on the deficiency due from the               
               On March 8, 2001, interest was assessed against petitioners.           
          On April 24, 2001, McKenney, who had been reassigned to                     
          petitioners’ cases, sent to petitioners letters estimating the              
          amount of tax petitioners would owe for 1995.  Additionally,                
          petitioners were made aware of the interest that was accruing on            
          their deficiencies.  In a letter dated April 26, 2001, Berger               
          requested that the IRS grant petitioners a 63-percent abatement             
          of interest on the deficiencies due to unreasonable IRS delays.             
          There was no Form 843, Claim for Refund and Request for                     
          Abatement, attached to this letter.  In letters dated May 3 and             

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