- 11 - proposed enforcement action. They failed to return the financial statement we sent them. Balancing Efficient Tax Collection and Intrusiveness Per IRC §6330(c)(3)(C), the determination by Appeals under this subsection shall take into consideration whether any proposed collection action balances the need for the efficient collection of taxes with the legitimate concern of the person that any collection action be no more intrusive than necessary. In this case, the taxpayers’ concern that the actions of the Compliance Division are unduly intrusive was weighed against the Service’s responsibility to apply the tax law fairly to all. Filing a lien or issuance of a levy always creates hardship for the taxpayer and is always intrusive. Even so, the lien or levy is sometimes necessary to collect the tax in the most efficient manner and/or to secure the Internal Revenue Service’s equity position in assets. The Notice of Federal Tax Lien will not be withdrawn. In the petition that petitioners filed commencing the instant case, petitioners stated: payments have been made yet no accounting has been provided. plaintiffs are currently unable to pay the remaining deficiency balance. plaintiffs request that the internal revenue service provide an accurate ac- counting of payments made and seek relief from interest and penalties, that all lien petitions be cancelled. [Reproduced literally.] Discussion The Court may grant summary judgment where there is no genuine issue of material fact and a decision may be rendered as a matter of law. Rule 121(b); Sundstrand Corp. v. Commissioner, 98 T.C. 518, 520 (1992), affd. 17 F.3d 965 (7th Cir. 1994). We conclude that there are no genuine issues of material factPage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 NextLast modified: November 10, 2007