T.C. Memo. 2003-271
UNITED STATES TAX COURT
EDWARD H. AND ANNE G. HARRELL, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 4063-02L. Filed September 17, 2003.
During the course of R’s initial review of Ps’
offer in compromise based upon doubt as to liability
for tax liabilities for 1991, 1992, and 1993, R’s
revenue officer communicated with a member of R’s
counsel’s office. In a review of R’s initial rejection
of Ps’ offer in compromise, R’s Appeals Officer
Petrohovich communicated with the member of R’s
counsel’s office who had previously provided advice to
R’s revenue officer. Following the rejection by R’s
Appeals Office of Ps’ offer in compromise, R issued to
Ps a notice of intent to levy. In response, Ps filed a
request for a hearing pursuant to sec. 6330, I.R.C.
The requested sec. 6330, I.R.C., hearing was conducted
by Appeals Officer Martin (AO Martin), who had no prior
involvement with the tax and tax periods involved in
the review. AO Martin determined that collection by
levy was appropriate and issued to Ps a “NOTICE OF
DETERMINATION CONCERNING COLLECTION ACTION(S) UNDER
SECTION 6320 and/or 6330”.
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