- 17 -
[petitioners’] Offer in Compromise” is without merit. One
Appeals officer’s prior involvement with respect to the unpaid
tax for a different period, at issue in a previous section 6330
hearing, is not imputed to all other Appeals officers who work in
the same Appeals Office as the Appeals officer with such prior
involvement. Consequently, AO Martin’s status as an impartial
officer is not compromised because she worked in the same Appeals
Office as AO Petrohovich, who conducted a previous section 6330
hearing regarding certain of petitioner’s tax years not here at
issue. Similarly, one Appeals officer’s prior involvement with
respect to the unpaid tax for the same period, at issue in the
review of an offer in compromise, is not imputed to all other
Appeals officers who work in the same Appeals Office as the
Appeals officer with such prior involvement. Consequently, AO
Martin’s status as an impartial officer is not compromised
because she worked in the same Appeals Office as AO Petrohovich,
who previously reviewed the Offer in Compromise outside the
context of a section 6330 hearing. We conclude that AO Martin
was an impartial officer as required by section 6330(b)(3).
Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 NextLast modified: May 25, 2011