- 8 -
In light of our resolution of respondent’s motion for
summary judgment, other arguments made by petitioner need not be
decided.
The determination of respondent’s Appeals officer properly
verified that the requirements of applicable law and
administrative procedures have been met, considered the issues
raised by petitioner, and balanced the need for efficient
collection of taxes with the legitimate concern of petitioner
that the collection action be no more intrusive than necessary.
As stated in the attachment to the notice of determination, the
Appeals officer considered all three of these factors under
section 6330(c)(3). Respondent’s Appeals officer did not abuse
her discretion under section 6330(c)(3). Further, no evidence
suggests any impropriety in the review by the Appeals manager of
the Appeals officer’s rejection of petitioner’s offer in
compromise.
1(...continued)
provides as follows:
The independent administrative review required for
rejected * * * [offers in compromise] will not be done
by Compliance on a CDP case. The required independent
review is done by the review of the Appeals manager and
signing of the Form 5402 * * *.
Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011