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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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