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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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