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adviser to all of respondent's employees, including Appeals
employees, on all matters pertaining to the interpretation,
administration, and enforcement of the internal revenue laws and
related statutes. Id. sec. 2, Q&A-11, 2000-2 C.B. at 406. Rev.
Proc. 2000-43, supra, contemplates that Appeals may obtain legal
advice from the Office of Chief Counsel, subject to certain
limitations, including that the advice should not be provided by
the same Chief Counsel field attorneys who advised the Internal
Revenue Service employee who made the determination that Appeals
is reviewing. Id. Appeals employees are further cautioned that,
while they may obtain legal advice from the Office of Chief
Counsel, they remain responsible for independently evaluating the
strengths and weaknesses of the specific issues presented by the
cases assigned to them and for making independent judgments
concerning the overall strengths and weaknesses of the cases.
Id. The limitations of Rev. Proc. 2000-43, supra, do not apply,
however, where a case has been docketed in this Court.8
Giving due consideration to the principles espoused in RRA
1998 section 1001(a) and Rev. Proc. 2000-43, supra, we are not
persuaded, in the context of the entire record in this case, that
there is reason to suspect that the independence of the Appeals
Office employees assigned to it was compromised by contacts with
8 Rev. Proc. 2000-43, sec. 2, Q&A-11, 2000-2 C.B. at 406,
further provides that cases docketed in this Court should instead
be handled in accordance with Rev. Proc. 87-24, 1987-1 C.B. 720.
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