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On April 13, 2001, petitioners’ case with respect to the
Notice of Intent to Levy was assigned to Appeals Officer Anne
Martin (AO Martin) in respondent’s Bailey’s Crossroads, Virginia,
office.
AO Martin previously worked directly under Appeals Chief
Gretes. Appeals Chief Gretes was the Appeals Chief for the
Virginia/West Virginia Appeals Office from September 27, 1997,
through August 13, 2000. From September 29, 1997, until October
1, 2000, AO Martin was in the chain of command of Appeals Chief
Gretes. After October 1, 2000, and at all times during her
review of petitioners’ case, AO Martin was not in a chain of
command that included Appeals Chief Gretes.
AO Martin had no involvement with respect to the underlying
tax liabilities at issue in petitioners’ case prior to her
assignment to the case.
On August 22, 2001, Mr. Crowgey and Acting Area 3 Director
of Appeals Brian O’Hanlon discussed the assignment of AO Martin
to petitioners’ case.
On August 28, 2001, AO Martin sent a letter to Mr. Crowgey
confirming a hearing date of September 20, 2001.
On January 22, 2002, respondent issued the Notice of
Determination that forms the basis for the instant case. The
Notice of Determination dealt with petitioners’ income tax
liabilities for tax years 1991, 1992, 1993, and 1999. The Notice
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