- 32 - Therefore, we conclude that petitioners have abandoned this argument. Petitioners continued to argue on brief that the notice of intent to levy was invalid against Mr. Andrews. However, petitioners’ concern that Mr. Andrews’s property will be levied against before the resolution of his innocent spouse case is without merit. In the notice of determination, respondent specifically stated that any activity against Mr. Andrews’s assets would be stayed until his pending innocent spouse case had been decided. 5. Efficient Collection Versus Intrusiveness Petitioners argue 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). Petitioners’ argument is not supported by the record. Petitioners have an outstanding tax liability. In their section 6330 hearing, petitioners 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 petitioners’ legitimate concern that collection be no more intrusive than necessary.Page: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 Next
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