- 20 - 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 thatPage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011