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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 the
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