- 7 - 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.Page: Previous 1 2 3 4 5 6 7 8Last modified: November 10, 2007