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determination for abuse of discretion. Sego v. Commissioner, 114
T.C. 604, 610 (2000); Goza v. Commissioner, 114 T.C. 176, 181
(2000). With exception of the issues identified and disposed of
above by the application of sections 6330(c)(4), 6330(c)(2)(B),
and 6402(f), petitioner has raised no other issue in this case.
Respondent's Appeals officer verified that respondent met
all applicable laws and administrative procedures, thereby
satisfying the requirements of section 6330(c)(1). Petitioner
has not challenged that determination except for the above-
mentioned claims we have already disposed of.
All the other requirements of section 6330(c)(3)(B) were
satisfied because petitioner did not raise any issue described in
section 6330(c)(2)(A)(i) (spousal defenses) or (ii) (challenges
to the appropriateness of collection actions).
The requirements of section 6330(c)(3)(C) are satisfied in
this case inasmuch as petitioner failed to offer any specific
collection alternatives, as described in section
6330(c)(2)(A)(iii). Respondent's Appeals officer determined that
the disputed actions of respondent properly balanced the need for
the efficient collection of taxes with the legitimate concern
that any collection be no more intrusive than necessary.
Petitioner has failed to assert specifically that the Appeals
officer's balancing determination was erroneous or to allege any
specific facts in support of any assertion to that effect. We
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