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to be considered. Petitioners’ argument is not supported by the
record.
Petitioners assert that they were “initially only given
weeks” to provide all information. However, they ignore the fact
that Ms. Cochran granted their requested extension and allowed
them until March 31, 2004, to submit information. Additionally,
petitioners have not identified any documents or other
information that they believe Ms. Cochran should have considered
but that they were unable to produce because of the deadline for
submission. Given the thoroughness and the amount of information
submitted, it is unclear why petitioners needed additional time.
We do not believe that Ms. Cochran abused her discretion by
establishing a deadline for the submission of information.
4. Mr. Andrews’ Pending Innocent Spouse Claim
At the time of the section 6330 hearing, Mr. Andrews had an
innocent spouse case pending before the Tax Court at docket No.
19705-02. In their petition, petitioners argued that, because of
Mr. Andrews’s pending innocent spouse claim: (1) Respondent
abused his discretion by considering the assets of both spouses;
and (2) the notice of intent to levy was invalid against Mr.
Andrews.
Petitioners did not argue on brief that respondent abused
his discretion by considering the assets of both spouses.
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