Ella Louise Wooten - Page 12

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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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