Edward H. and Anne G. Harrell - Page 1

                                 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                     
               SECTION 6320 and/or 6330”.                                             

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