Daniel O. Abelein - Page 19

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               Petitioner asserts that he was “initially only given four              
          weeks” to provide all information.  However, he ignores the fact            
          that Ms. Cochran granted his requested extension and allowed him            
          until April 6, 2004, to submit information.  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.  We do not             
          believe that Ms. Cochran abused her discretion by establishing a            
          deadline for the submission of information.                                 
               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 not less intrusive means for respondent to consider.  We               
          find that respondent balanced the need for efficient collection             
          of taxes with petitioner’s legitimate concern that collection be            
          no more intrusive than necessary.                                           






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