- 24 - alternative on that basis, we have found no abuse of discretion. See Schulman v. Commissioner, T.C. Memo. 2002-129; see also Etkin v. Commissioner, T.C. Memo. 2005-245; Schenkel v. Commissioner, T.C. Memo. 2003-37. Balancing Efficient Collection and Intrusiveness Petitioners also argue that the Appeals officer failed to balance the need for efficient collection of taxes with petitioners' legitimate concern that any collection action be no more intrusive than necessary, as required under section 6330(c)(3)(C). We disagree. In the case of installment agreements and offers-in-compromise, respondent has established relatively detailed guidelines for his employees to follow in considering these collection alternatives. The Appeals officer and offer specialist did so in this case; indeed, the undisputed record indicates that both conducted extensive discussions with Mr. Lemann, offered suggestions regarding how petitioners might avoid levy, and solicited evidence of any special circumstances. The two collection alternatives petitioners offered fell substantially short of their ability to pay as determined under respondent's prescribed guidelines. Upon learning this, petitioners offered no others. Their delinquent tax liabilities are likewise substantial, and they have previously defaulted on an installment agreement. We are satisfied that the Appeals officer struck the appropriate balance, especially given thePage: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Next
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