J. Jean Moore - Page 5

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               With the filing of her OIC, petitioner did not make any                
          payment to respondent, but petitioner did offer to pay the                  
          $258,000 within 90 days of respondent’s acceptance of her OIC.3             
          Petitioner planned to sell assets in order to obtain the                    
               On April 15, 2004, petitioner paid respondent the final                
          $79,166 she owed relating to her criminal conviction, and                   
          petitioner asked that the $79,166 be credited toward the $258,000           
          she would owe under the pending OIC.                                        
               In connection with the Appeals Office’s consideration of               
          petitioner’s OIC, a number of communications about petitioner               
          occurred among respondent’s Appeals officer, an offer specialist            
          assigned to work on petitioner’s OIC, and two of respondent’s               
          revenue officers, one of whom worked in California and one of               
          whom worked in Oregon.  Before petitioner’s CDP hearing with                
          respondent’s Appeals officer, both of these revenue officers had            
          been involved in attempting to collect petitioner’s outstanding             
          taxes for the years in issue.  The communications between                   
          respondent’s Appeals officer and the offer specialist, on the one           
          hand, and respondent’s two revenue officers, on the other,                  

               3  By Mar. 11, 2004, petitioner had paid respondent $170,834           
          due as a result of the criminal conviction relating to her 1992             
          through 1995 Federal income taxes, which amount is separate from            
          the $258,000 petitioner offered to pay respondent under the                 

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