- 16 - explicit deadlines that respondent generously extended for petitioner’s benefit. The Court concludes that respondent did not abuse his discretion by: (1) Failing to take into account information respondent requested of the estate and that the estate failed to produce; and (2) proceeding with the collection hearing despite the estate’s lack of files. See Morlino v. Commissioner, T.C. Memo. 2005-203; Roman v. Commissioner, supra. The estate also alleges that Mr. Feist spent a “grossly inadequate period of time” considering the case. The regulations promulgated under section 6330 provide that there is no period of time within which the Appeals Office must conduct a collection hearing or issue a notice of determination. The regulations provide, in pertinent part, that while there is no set time deadline to conduct the Appeals hearing, “Appeals will, however, attempt to conduct a CDP hearing and issue a Notice of Determination as expeditiously as possible under the circumstances.” Sec. 301.6330-1(e)(3), Q&A-E9, Proced. & Admin. Regs. “[T]here is neither requirement nor reason that the Appeals officer wait a certain amount of time before rendering his determination as to a proposed levy.” Clawson v. Commissioner, T.C. Memo. 2004-106; see Murphy v. Commissioner, supra at 322; Manjourides v. Commissioner, T.C. Memo. 2005-242; Morlino v. Commissioner, supra.Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 NextLast modified: November 10, 2007