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rejecting the offer in compromise based on doubt as to
collectibility.
C. The Appeals Officer Did Not Improperly and Prematurely
Conclude the Hearing
1. Introduction
On brief, petitioner argues not only that Ms. Boudreau
prematurely concluded the hearing but also that she (1) did not
conduct the hearing in good faith, (2) failed to negotiate during
consideration of the offer, (3) was inflexible in considering
petitioner’s case, (4) was biased in concluding that the hearing
had to be promptly concluded, and (5) was not impartial since she
both conducted the hearing and negotiated the offer. Petitioner
further argues bias in the section 6330 hearing procedures
because (1) there was no administrative review of Ms. Boudreau’s
rejection of the offer, and (2) petitioner had no right to appeal
Ms. Boudreau’s rejection of the offer.
2. Hearing Was Not Prematurely Concluded
In Clawson v. Commissioner, T.C. Memo. 2004-106, fewer than
3 months passed between the taxpayer's filing a request for a
section 6330 hearing concerning a proposed levy and an adverse
determination by the Appeals officer. Approximately 1 month
passed after the Appeals officer's offer of a telephonic
conference until the adverse determination, and only 9 days
passed after the telephone conference until the adverse
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