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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.
16(...continued)
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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