Edward H. and Anne G. Harrell - Page 2

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               Guy C. Crowgey, for petitioners.                                       
               Mary Ann Waters, for respondent.                                       


                           SUPPLEMENTAL MEMORANDUM OPINION                            

               NIMS, Judge:  Respondent moves the Court for reconsideration           
          of its Memorandum Opinion at T.C. Memo. 2003-271.  See Rule 161.            
          Unless otherwise indicated, all section references are to the               
          Internal Revenue Code in effect at all relevant times, and all              
          Rule references are to the Tax Court Rules of Practice and                  
          Procedure.                                                                  
               In Harrell v. Commissioner, T.C. Memo. 2003-271, we held               
          that Appeals Officer Martin (AO Martin) was an impartial officer            
          at the time she conducted the section 6330 hearing at issue in              
          this case.  We further held that AO Martin did not abuse her                
          discretion in determining that the communications between Appeals           
          Officer Barbara Petrohovich and Deborah Stanley, an attorney in             
          respondent’s counsel’s office, did not violate petitioners’                 
          rights.  We also remanded this case to the Commissioner for the             
          sole purpose of permitting petitioners to reconsider their                  
          rejection of AO Martin’s suggested installment agreement, which             
          was based in part on petitioners’ required concession of their              
          1991, 1992, and 1993 tax liabilities, or to offer another                   
          collection alternative pursuant to section 6330(c)(2)(A)(iii).              
          Id.                                                                         





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