Merry J. Chandler - Page 9

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          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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