- 24 -
face-to-face hearing in this case would not have been, nor would
it be, productive. See Lunsford v. Commissioner, 117 T.C. 183,
189 (2001). There is simply no requirement that a face-to-face
hearing must be offered to a taxpayer who merely wishes to pursue
a tax protest agenda.
Furthermore, the record reflects that respondent properly
verified that the requirements of applicable law and
administrative procedures were met and that he balanced the need
for efficient collection of taxes with the legitimate concern
that the collection action be no more intrusive than necessary.
See sec. 6330(c)(3). Accordingly, respondent’s determination to
proceed with the proposed levy was appropriate.
After carefully reviewing the record, respondent did not
abuse his discretion in sustaining the notice of intent to levy
as to petitioner. We are satisfied that there is no genuine
issue as to any material fact, and a decision may be rendered as
a matter of law. Accordingly, we shall grant respondent’s Motion
For Summary Judgment, filed August 12, 2005, and supplemented
November 30, 2005, and January 13, 2006, and thereby sustain the
notice of determination, subject to respondent’s concession of
the addition to tax under section 6651(a)(2) and interest
thereon.
13(...continued)
Federal tax laws.
Page: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NextLast modified: May 25, 2011