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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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