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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.
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