- 19 - We turn now to the argument of Mr. Gazi and Ms. Gazi’s estate that respondent abused respondent’s discretion in making the determinations in the notice of determination because the settlement officer refused “to grant Petitioner additional time to submit an Offer in Compromise as a collection alternative in this matter.” There is no requirement that the Commissioner wait a certain amount of time before making a determination as to a proposed levy. See sec. 301.6330-1(e)(3), Q&A-E9, Proced. & Admin. Regs.9 Section 301.6330-1(e)(3), Q&A-E9, Proced. & Admin. Regs., provides that there is no period of time within which the Appeals Office must conduct a hearing under section 6330 or issue a notice of determination under that section and that “Appeals will * * * attempt to conduct a * * * [hearing under section 6330] and issue a Notice of Determination as expeditiously as possible under the circumstances.” On the record before us, we find that the settlement offi- cer’s refusal (1) to reschedule the Appeals Office hearing from May 15, 2006, to at least one week later and (2) to consider further collection alternatives proposed by the taxpayer was reasonable in light of the circumstances presented. In the settlement officer’s March 27, 2006 letter, the settlement officer offered Mr. Gazi and Ms. Gazi’s estate the opportunity to have a face-to-face Appeals Office hearing on April 25, 2006, and 9See also Clawson v. Commissioner, T.C. Memo. 2004-106.Page: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 NextLast modified: March 27, 2008