Donald Ertz - Page 34

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          petitioner to show that respondent abused his discretion.  The              
          burden was not on respondent to provide enough information to               
          show that he did not abuse his discretion.  Nevertheless, we find           
          that we had more than sufficient information to review                      
          respondent’s determination.                                                 
               3.   Scheduling of the Section 6330 Hearing and Deadline for           
                    Submission of Documents                                           
               Petitioner argues that Ms. Cochran abused her discretion by            
          not allowing his counsel additional time to prepare for the                 
          section 6330 hearing and to submit additional documentation.                
          Once the section 6330 hearing was scheduled, Ms. Cochran refused            
          petitioner’s request to delay the hearing.  However, Ms. Cochran            
          did extend the deadline for submission of documents.                        
               While petitioner wanted to delay the section 6330 hearing,             
          he does not allege that he was unable to adequately prepare for             
          the hearing.  Additionally, petitioner has not identified any               
          documents or other information that he believes Ms. Cochran                 
          should have considered but that he was unable to produce because            
          of the deadline for submission.  Given the thoroughness and the             
          amount of information submitted, it is unclear why petitioner               
          needed additional time.  We do not believe that Ms. Cochran                 




               14(...continued)                                                       
          Restructuring and Reform Act of 1998, Pub. L. 105-206, sec.                 
          3001(c), 112 Stat. 727.                                                     




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