Michael Keller - Page 20

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               3.   Efficient Collection Versus Intrusiveness                         
               Petitioner argues that respondent failed to balance 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)(C).  Petitioner’s argument is not supported             
          by the record.                                                              
               Petitioner has an outstanding tax liability.  In his second            
          section 6330 hearing, petitioner proposed only an effective tax             
          administration offer-in-compromise.  In the notice, respondent              
          states:  “the only other alternative is to pay his accounts by              
          means of an installment agreement.  Through his authorized                  
          representative he has indicated he does not want to consider this           
          alternative at this time.”  Respondent concludes:                           
               Since we are unable to resolve his accounts by mutually                
               agreeable collection alternatives, the only alternative                
               is to sustain the levy action proposed to collect his                  
               accounts.  This action balances the need for efficient                 
               collection of taxes with the legitimate concern of the                 
               taxpayer that the collection action be no more                         
               intrusive than necessary.                                              
               The supplemental notice of determination indicates that                
          respondent sought to collect petitioner’s outstanding tax                   
          liability through less intrusive means (an installment                      
          agreement), but petitioner rejected it.  Because no other                   
          collection alternatives were proposed, there were not less                  
          intrusive means for respondent to consider.  We find that                   







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