Greg Griffin - Page 8




                                        - 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.                                   



















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