Arthur A. Lemann III and Roberta A. Lemann - Page 24

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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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