Merry J. Chandler - Page 4

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          record of actions that he took with respect to the request that             
          he considered to be significant, including correspondence and               
          other contacts with petitioner and the final disposition of the             
          request (the case activity record).  The entry in the case                  
          activity record for October 12, 2001, chronicles a telephone                
          conversation with petitioner.  In pertinent part, it states:                
          “Personal conference is not necessary per [petitioner].                     
          Telephone discussion will be fine.”  The remainder of the entry             
          discusses (1) an offer in compromise that petitioner claimed to             
          have filed, but as to which Mr. McNichol could find no evidence             
          in an Internal Revenue Service (IRS) database, and (2) Mr.                  
          McNichol’s advice to petitioner that, before an offer in                    
          compromise could be considered, she must file her 2000 return.              
               Mr. McNichol’s entry in the case activity record for                   
          December 4, 2001, states that petitioner filed her 2000 return              
          and that the IRS received an offer in compromise from petitioner.           
          The entry states that there were problems with the offer and that           
          Mr. McNichol sent a letter to petitioner asking for revisions to            
          the offer and for additional information; the entry further                 
          states that petitioner would be allowed 30 days to respond.  An             
          entry for January 2, 2002, states that there had been no word               
          from petitioner and that Mr. McNichol had determined to sustain             
          the collection (levy) action.  A further entry for that date                
          states that Mr. McNichol had prepared the case for closing.                 

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