Gary W. McDonough - Page 29

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         petitioner to show that respondent abused his discretion.  The               
         burden was not on respondent to provide enough information to                
         show that he did not abuse his discretion.  Nevertheless, this               
         Court finds that it had more than sufficient information to                  
         review respondent’s determination.                                           
                   3.   Scheduling of the Section 6330 Hearing and                    
                        Deadline for Submission of Documents                          
              Petitioner argues that Ms. Cochran abused her discretion by             
         not allowing his counsel additional time to prepare for the                  
         section 6330 hearing and to submit additional documentation.                 
         Once the section 6330 hearing was scheduled, Ms. Cochran refused             
         petitioner’s request to delay the hearing.  However, Ms. Cochran             
         did extend the deadline for submission of documents.                         
              While petitioner wanted to delay the section 6330 hearing,              
         he does not allege that he was unable to adequately prepare for              
         the hearing.  Additionally, petitioner has not identified any                
         documents or other information that he believes Ms. Cochran                  
         should have considered but that he was unable to produce because             
         of the deadline for submission.  Given the thoroughness and the              
         amount of information submitted, it is unclear why petitioner                
         needed additional time.  This Court does not believe that Ms.                

          because respondent’s examination of petitioner’s returns did not            
          commence after July 22, 1998.  See Internal Revenue Service                 
          Restructuring and Reform Act of 1998, Pub. L. 105-206, sec.                 
          3001(c), 112 Stat. 727.                                                     

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