Gary W. McDonough - Page 30

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         Cochran abused her discretion by establishing a timeframe for the            
         section 6330 hearing and the submission of documents.                        
                   4.   Efficient Collection Versus Intrusiveness                     
              Petitioner argues that respondent failed to balance the need            
         for efficient collection of taxes with the legitimate concern                
         that the collection action be no more intrusive than necessary.              
         See sec. 6330(c)(3)(C).  Petitioner’s argument is not supported              
         by the record.                                                               
              Petitioner has an outstanding tax liability.  In his section            
         6330 hearing, petitioner proposed only an offer-in-compromise.               
         Because no other collection alternatives were proposed, there                
         were no less intrusive means for respondent to consider. The                 
         Court finds that respondent balanced the need for efficient                  
         collection of taxes with petitioner’s legitimate concern that                
         collection be no more intrusive than necessary.                              
              In reaching these holdings, the Court has considered all                
         arguments made and, to the extent not mentioned, concludes that              
         they are moot, irrelevant, or without merit.                                 
              To reflect the foregoing,                                               


                                                       Decision will be               
                                                 entered for respondent.              









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