Legal Opinion

Harrell v. Comm'r

United States Tax Court

Decided September 17, 2003No. 4063-02LUnpublishedCited by 1 opinion

During the course of R's initial review of Ps' offer in compromise based upon doubt as to liability for tax liabilities for 1991, 1992, and 1993, R's revenue officer communicated with a member of R's counsel's office. In a review of R's initial rejection of Ps' offer in compromise, R's Appeals Officer Petrohovich communicated with the member of R's counsel's office who had previously provided advice to R's revenue officer.

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During the course of R's initial review of Ps' offer in compromise based upon doubt as to liability for tax liabilities for 1991, 1992, and 1993, R's revenue officer communicated with a member of R's counsel's office. In a review of R's initial rejection of Ps' offer in compromise, R's Appeals Officer Petrohovich communicated with the member of R's counsel's office who had previously provided advice to R's revenue officer. Following the rejection by R's Appeals Office of Ps' offer in compromise, R issued to Ps a notice of intent to levy. In response, Ps filed a request for a hearing pursuant…

1Opinion of the Court

EDWARD H. AND ANNE G. HARRELL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Harrell v. Comm'r

No. 4063-02L

United States Tax Court

T.C. Memo 2003-271; 2003 Tax Ct. Memo LEXIS 272; 86 T.C.M. (CCH) 378;

September 17, 2003, Filed

Case was remanded to Commissioner.

During the course of R's initial review of Ps' offer in

compromise based upon doubt as to liability for tax liabilities

for 1991, 1992, and 1993, R's revenue officer communicated with

a member of R's counsel's office. In a review of R's initial

rejection of Ps' offer in compromise, R's Appeals Officer

Petrohovich communicated with…

2Cases cited6 opinions

  1. Goza v. CommissionerUnited States Tax Court · 2000
  2. Young v. United StatesSupreme Court of the United States · 2002
  3. Landry v. CommissionerUnited States Tax Court · 2001
  4. Downing v. Comm'rUnited States Tax Court · 2002
  5. Young v. United StatesCourt of Appeals for the First Circuit · 2000

1 more not listed; retrieve them via the Exa API.

3Cited by1 opinion

  1. Carlson v. United StatesDistrict Court, D. Massachusetts · 2005

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