Scott Roman - Page 13

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          Mr. Karaszkiewicz initially stated he would try to supply the               
          materials and the March 26, 2003, date on which Mr. Karaszkiewicz           
          said the information would be “quickly” provided.  Moreover, we             
          note that it is more than 2 years after petitioner’s initial                
          submission of an offer in compromise.  In these circumstances,              
          and especially in light of the absence of any further                       
          communication from petitioner to alter the implications of the              
          “quickly” language, waiting for 6 weeks falls within the bounds             
          of reasonableness.                                                          
               Section 6330 entitles taxpayers to “a hearing”.  No                    
          statutory or regulatory provision requires that taxpayers be                
          afforded an unlimited opportunity to supplement the                         
          administrative record.  Nor are petitioner’s contentions                    
          regarding lack of warning well taken where the record in this               
          case is replete with explicit deadlines that respondent                     
          generously extended for petitioner’s benefit.  The statute only             
          requires that a taxpayer be given a reasonable chance to be heard           
          prior to the issuance of a notice of determination.  The                    
          consideration of petitioner’s case thus did not fail to comply              
          with the terms for a fair hearing set forth in section 6330.                
               Consequently, we conclude that there was no abuse of                   
          discretion in respondent’s decision to reject petitioner’s offer            
          in compromise.  In absence of the requested information,                    
          respondent was unable reasonably to determine that petitioner’s             

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