Edward F. Murphy - Page 42

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          See sec. 6330(d).  In response to these same arguments, the Court           
          of Appeals for the First Circuit has said:                                  
               Represented by counsel, * * * [the taxpayer] decided to                
               submit his offer in compromise to the IRS Office of                    
               Appeals pursuant to � 6330 in the first instance.                      
               Under � 6330, he had no right to more than one hearing                 
               nor to a hearing before anyone other than the Office of                
               Appeals.  See 26 U.S.C. � 6330(b) (2000).  Moreover, if                
               a taxpayer desires to challenge an appeals officer's                   
               determination, � 6330 provides for judicial review,                    
               which * * * [the taxpayer] elected to pursue, not                      
               another administrative appeal.  Id. � 6330(d).                         
          Olsen v. United States, supra at 157.  Petitioner’s complaint is            
          without merit.                                                              
                    4.  Conclusion                                                    
               We find no merit in petitioner’s arguments that Ms. Boudreau           
          improperly and prematurely concluded the hearing.                           
               D.  Conclusion                                                         
               Ms. Boudreau did not abuse her discretion in determining               
          that respondent may proceed by levy to collect the unpaid tax.              
          VII.  Conclusion                                                            
               To reflect the foregoing,                                              

                                                  Decision will be entered            
                                             for respondent.                          












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