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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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