- 34 - 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.Page: Previous 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 Next
Last modified: May 25, 2011