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”.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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