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(C) whether any proposed collection action balances the need for
the efficient collection of taxes with the legitimate concern of
the person that any collection be no more intrusive than
necessary.
Here, the Appeals officer addressed all these matters.
He satisfied the first requirement by reviewing the Internal
Revenue Service transcripts of petitioner’s account. Hill v.
Commissioner, T.C. Memo. 2002-272; Weishan v. Commissioner, T.C.
Memo. 2002-88; Kuglin v. Commissioner, T.C. Memo. 2002-51.
The Appeals officer satisfied the second requirement by
considering the issues raised by petitioner. The only issue
raised by petitioner was his inability to pay the liability in
full, and, in that regard, petitioner requested that he be
allowed to satisfy the liability through an offer in compromise.
The Appeals officer addressed this request by reviewing the
information submitted, explaining that it was incomplete, and
asking for additional information. Petitioner failed to submit a
properly completed Form 656, Offer in Compromise, and the
required financial information for the consideration of his
request.
As to the third requirement, the Appeals officer properly
balanced the need for efficient collection of taxes through the
proposed levy against the concern that any collection action be
no more intrusive than necessary. Petitioner failed to provide
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Last modified: May 25, 2011