- 42 -
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.
Page: Previous 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 Last modified: May 25, 2011