Edward H. and Anne G. Harrell - Page 17

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          [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).                 














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