- 9 -
interview, that, indeed, she did wish such an interview, we are
unconvinced that she communicated that fact to Mr. McNichol.
IV. Conclusion
As we understand her underlying claim, petitioner argues
that she should be allowed to make (and Appeals should accept) an
offer in compromise of the unpaid liabilities. Petitioner
attempted to make an offer in compromise, but Mr. McNichol found
problems with the offer and asked petitioner to revise it and to
provide him with additional information. Mr. McNichol gave
petitioner 30 days to do so. At the end of 30 days, when
petitioner had failed to make the revisions or provide the
additional information, Mr. McNichol took steps to close
petitioner’s case and deny the request. It took more than 6
weeks for Appeals to close the case and issue the determination.
Despite the additional 6 weeks, petitioner never revised the
offer or provided the additional information. We do not think
that Appeals abused its discretion in determining to proceed to
collect the unpaid liabilities by levy. See Roman v.
Commissioner, T.C. Memo. 2004-20 (reasonable to issue adverse
section 6330 determination when, after 6 weeks, taxpayer had
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