Edward H. and Anne G. Harrell - Page 9

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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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