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abused her discretion by establishing a timeframe for the section
6330 hearing and the submission of documents.
4. Efficient Collection Versus Intrusiveness
Petitioner argues 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). Petitioner’s argument is not supported
by the record.
Petitioner has an outstanding tax liability. In his section
6330 hearing, petitioner 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 petitioner’s legitimate concern that collection be no
more intrusive than necessary.
II. Interest on Tax-Motivated Transactions
Section 6621(c) applies an increased rate of interest on
substantial underpayments of tax resulting from tax-motivated
transactions. For purposes of section 6621(c), a “substantial
underpayment attributable to tax motivated transactions” means
any underpayment of tax attributable to one or more tax-motivated
transactions if the amount of the underpayment exceeds $1,000.
Sec. 6621(c)(2). Tax-motivated transactions include any
valuation overstatements within the meaning of former section
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