Judy Hedrick Blosser - Page 6

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          T.C. 19, 23 (1999).  Because petitioner does not dispute her                
          underlying tax liability, we apply the abuse of discretion                  
               Under section 6330(c)(3), in making a determination the                
          Appeals Office must (1) verify that the requirements of                     
          applicable law and administrative procedures have been met, (2)             
          consider the issues the taxpayer raised at the hearing, including           
          collection alternatives, and (3) determine whether any proposed             
          collection action balances the need for the efficient collection            
          of taxes with the legitimate concern of the person that any                 
          collection be no more intrusive than necessary.  Petitioner                 
          argues only that the Appeals Office abused its discretion by                
          failing to consider the collection alternative she proposed                 
          during the telephone hearing.                                               
               The Internal Revenue Manual states that settlement officers            
          may not consider collection alternatives unless the taxpayer has            
          provided adequate financial information, such as the filing of a            
          current CIS, and has filed all required tax returns.  See 2                 
          Administration, Internal Revenue Manual (CCH), sec.                         
, at 17,810; sec., at 17,653.  Petitioner             
          does not object to this policy, and we have found it to be                  
          reasonable.  See Estate of Atkinson v. Commissioner, T.C. Memo.             
          2007-89.  It is also the policy of the Appeals Office to request            
          a new CIS if the taxpayer’s financial condition changes after the           

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