- 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 Next
Last modified: May 25, 2011