- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 Next
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