Roger and Lora Carter - Page 6

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          various arguments regarding the appropriateness of an offer-in-             
          compromise.                                                                 
               On October 31, 2003, petitioners’ case was assigned to                 
          Settlement Officer Linda Cochran (Ms. Cochran).                             
               On February 13, 2004, petitioners submitted a letter (the              
          February 2004 letter) to Ms. Cochran.  Petitioners described                
          their involvement in the Hoyt partnerships and made various                 
          assertions regarding equity and public policy considerations.               
          Petitioners attached several exhibits to the February 2004                  
          letter.                                                                     
               On March 8, 2004, Ms. Cochran sent petitioners a letter                
          scheduling a telephone section 6330 hearing for March 31, 2004.             
          Petitioners’ representative, Terri A. Merriam (Ms. Merriam),                
          requested that the hearing be delayed due to the number of Hoyt-            
          related cases her law firm was handling.  Ms. Cochran did not               
          change the date of the hearing, but extended petitioners’                   
          deadline for producing information to be considered to May 14,              
          2004.                                                                       
               On May 14, 2004, petitioners submitted to Ms. Cochran a Form           
          656, Offer in Compromise, a Form 433-A, Collection Information              
          Statement for Wage Earners and Self-Employed Individuals, and               
          three letters (the May 14, 2004 letters) explaining the offer               
          amount and other payment considerations and setting out in detail           
          petitioners’ position regarding the offer-in-compromise.                    






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