- 30 - 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.Page: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30
Last modified: May 25, 2011