Edward F. Murphy - Page 36

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          determination.  The taxpayer argued that the Appeals officer                
          abused his discretion because he reached his decision to sustain            
          the proposed levy in “barely one month” after he contacted                  
          petitioners.  We held:  “[T]here is neither requirement nor                 
          reason that the Appeals officer wait a certain amount of time               
          before rendering his determination as to a proposed levy.”  As              
          authority, we cited section 301.6330-1(e)(3), Q&A-E9, Proced. &             
          Admin. Regs., which provides that there is no period of time in             
          which Appeals must conduct a section 6330 hearing or issue a                
          notice of determination:  “Appeals will, however, attempt to                
          conduct a * * * [section 6330 hearing] and issue a Notice of                
          Determination as expeditiously as possible under the                        
          circumstances.”                                                             
               In this case, Ms. Boudreau reached her decision that                   
          respondent’s collection action should stand more than 8 months              
          after she was assigned to petitioner’s case.  On being assigned             
          to the case, she contacted petitioner’s representative, Mr.                 
          Burke, and promptly met with him.  She received from him an offer           
          in compromise and certain supporting information.  She requested            
          from him additional information and documents necessary for her             
          to review the offer.  Mr. Burke missed numerous due dates for               
          submitting additional information, and, on one occasion, she                
          closed the case because of Mr. Burke’s failure to meet submission           
          due dates.  It took Mr. Burke more than 4 months to provide to              






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