- 12 - 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. WePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011