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on that issue. Consequently, petitioner is not the prevailing
party and is not entitled to an award of litigation costs
pursuant to section 7430. We need not decide whether petitioner
exhausted administrative remedies, whether petitioner
unreasonably protracted the court proceedings, or whether the
claimed litigation costs are reasonable.
VI. Conclusion
The record demonstrates that respondent’s Appeals Office (1)
verified that the requirements of applicable laws and
administrative procedures had been met, (2) properly addressed
the issues raised by petitioner during the initial section 6330
hearing and the section 6330 hearing on remand, and (3) and
balanced the need for the efficient collection of taxes with the
concern that the collection action be no more intrusive than
necessary. Consequently, we hold that the decision of
respondent’s Appeals Office to sustain the proposed levy against
petitioner is not an abuse of discretion. Accordingly, we hold
that petitioner is not entitled to an award of litigation costs
as the prevailing party. Additionally, petitioner’s “Motion to
Compel Settlement” will be denied. We have considered all of the
parties’ contentions. To the extent not addressed herein, such
contentions are without merit or are unnecessary to reach.
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