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and the amount of information submitted, it is unclear why
petitioners needed additional time. We do not believe that Ms.
Cochran abused her discretion by establishing a timeframe for the
section 6330 hearing and the submission of information.
4. 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 no 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.
D. Conclusion
Petitioners have not shown that respondent’s determination
was arbitrary or capricious, or without sound basis in fact or
law. For all of the above reasons, we hold that respondent’s
determination was not an abuse of discretion, and respondent may
proceed with the proposed collection action.
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