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his economic hardship. Moreover, even if respondent used all the
expenses petitioner submitted with the claim, petitioner’s second
offer was still unreasonably low. Accordingly, respondent did
not abuse his discretion by rejecting petitioner’s second offer.
Under section 6320, the Appeals officer must consider
collection alternatives as well as whether any proposed
collection action balances the need for efficient collection of
taxes with the legitimate concern that collection be no more
intrusive than necessary. Secs. 6320(c), 6330(c)(2)(A)(iii),
(3)(C). Even considering the circumstances in a light most
favorable to petitioner, petitioner had the ability to pay over
$36,000 yet offered only $2,200 to compromise the outstanding
$38,165.32 tax liability. Petitioner suggested no reasonable
collection alternatives and would not even entertain any
collection alternative that did not involve the removal of the
Federal tax lien. In light of petitioner’s inflexible stance,
respondent’s collection activity was no more intrusive than
necessary. The Appeals officer thus complied with the
requirements of sections 6320(c) and 6330(c) when he conducted
the hearing and made a determination to keep in place the lien
on petitioner’s assets.
Petitioner has the ability to pay his undisputed tax
liability. Most of the liabilities that respondent is attempting
to collect were due with the self-assessed returns petitioner
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