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the addition to tax in a separate administrative proceeding. We
need not determine whether the request for abatement was
appropriately precluded because it was raised by petitioner and
considered and rejected by respondent. Indeed, the determination
letter states that “We have reviewed your request for abatement
of the penalty and have concluded that the decision of the
appellate conferee was correct and not an abuse of discretion.
We did not find that your failure to pay the estate tax was due
to reasonable cause.” The estate failed to establish reasonable
cause for its failure to pay timely the estate tax. We conclude
that this determination was not an abuse of discretion.
III. Court Review of Collection Alternatives
It was appropriate for respondent to consider the estate’s
request for an extension insofar as it was proposed or considered
as a collection alternative. We conclude that respondent’s
rejection of such request was not an abuse of discretion.
Respondent is required, pursuant to section 6330(c)(3)(C),
to consider “whether any proposed collection action balances the
need for the efficient collection of taxes with the legitimate
concern of the person that any collection action be no more
intrusive than necessary.” See also H. Conf. Rept. 105-599 at
264 (1998), 1998-3 C.B. 747, 1018. Respondent did so, even
though his consideration of this issue was sometimes couched as a
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