Roger and Lora Carter - Page 34

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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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