Estate of Carol Andrews, Deceased, Robert Andrews, Special Administrator, and Robert Andrews - Page 32

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          Therefore, we conclude that petitioners have abandoned this                 
               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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