D. Jean Bartelma and Dan F. Bartelma - Page 5

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          May 4, 2001, McKenney stated that the requested interest                    
          abatement was unreasonable.  However, he did include the forms              
          and procedures necessary for petitioners to file a claim                    
          properly.  Additionally, McKenney recommended that petitioners              
          “pay at least the tax due and the amount of interest that you               
          reasonably believe you owe” in order to avoid additional interest           
               Petitioners filed Forms 843 on or about May 9, 2001,                   
          requesting a 75-percent abatement of interest.  On May 17, 2001,            
          petitioners’ voluntary payments of the tax deficiencies were                
          posted to their accounts.  These payments included the tax                  
          estimated as owed plus what petitioners asserted to be a                    
          reasonable amount of interest, that being 25 percent of the                 
          interest quoted in the April 24, 2001, letters from McKenney.               
          Petitioners had the ability to pay the entire amount due at the             
          time that they made their voluntary payments.  However, they                
          believed that the amount of interest was unreasonable.                      
               As of May 17, 2001, McKenney was also working on                       
          petitioners’ 1993, 1994, and 1996 taxable years.  Between May 17,           
          2001, and October 31, 2001, McKenney was unable to obtain Audit             
          Information Management System (AIMS) controls, which allow agents           
          to control their cases, for petitioners’ accounts.  McKenney                
          determined that the process of obtaining AIMS controls should               
          have taken only 90 days.  Therefore, on December 19, 2001, the              

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