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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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