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The Appeals officer balanced the need for efficient
collection of taxes against petitioner’s concern over the
action’s intrusiveness.
Had petitioner proceeded with the hearing, an alternative
collection action might have been considered. The Court notes
that there was sufficient evidence introduced at trial indicating
that if petitioner goes through the proper procedural steps
(i.e., requesting audit reconsideration or submitting an offer-
in-compromise), he might receive administrative relief.
Therefore, the Court concludes that respondent’s Appeals
officer did not abuse her discretion in upholding the filing of
the NFTL and the proposed levy action. Accordingly, respondent’s
determination is sustained.
To reflect the foregoing,
An appropriate decision will
be entered.
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Last modified: November 10, 2007