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submitted.4 While the final 2-week deadline may seem short when
considered in isolation, we do not consider it in isolation.
Rather, we consider it in context, see, e.g., Roman v.
Commissioner, T.C. Memo. 2004-20, which context includes the
longer period that petitioner had to comply with Mr. O’Shea’s
requests and the fact that there is no evidence that either
petitioner or Mr. Burke protested the deadline or asked for any
extension. If there is fault here, it lies not with Mr. O’Shea
in setting a deadline of September 2, 2003.
C. Other Arguments
1. Introduction
On brief, petitioner describes the following errors, which
are either in addition to or supplement his principal assignment
of error, that Mr. O’Shea abused his discretion by prematurely
concluding the section 6330 hearing: (1) Mr. O’Shea was biased
by his belief that the hearing had to be promptly concluded, (2)
respondent did not conduct the hearing in good faith, (3)
respondent was not flexible in considering petitioner’s matter,
(4) the lack of ascertainable standards to be followed at section
6330 hearings violates due process, and (5) Mr. O’Shea was not
4 In addition to referencing the offer in compromise that
petitioner submitted on Nov. 20, 2002, and which was rejected on
Jan. 15, 2003, the record contains a copy of another rejected
offer in compromise, signed by petitioner on July 9, 2001, and
relating to trust fund recovery penalties imposed with respect to
employment taxes due in 1997.
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