Franklin and Janetta Hubbart - Page 32

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          to be considered.  Petitioners argument is not supported by the             
          record.                                                                     
               Petitioners assert that they were “initially only given                
          weeks” to provide all information.  However, they ignore the fact           
          that Ms. Cochran granted their requested extension and allowed              
          them until April 9, 2004 to submit information.  Additionally,              
          petitioners have not identified any documents or other                      
          information that they believe Ms. Cochran should have considered            
          but that they were unable to produce because of the deadline for            
          submission.  Given the thoroughness and the amount of information           
          submitted, it is unclear why petitioners needed additional time.            
          We do not believe that Ms. Cochran abused her discretion by                 
          establishing a deadline for the submission of information.                  
               4.   Efficient Collection Versus Intrusiveness                         
               Petitioners argue that respondent failed to balance the need           
          for efficient collection of taxes with the legitimate concern               
          that the collection action be no more intrusive than necessary.             
          See sec. 6330(c)(3)(C).  Petitioners’ argument is not supported             
          by the record.                                                              
               Petitioners have an outstanding tax liability.  In their               
          section 6330 hearing, petitioners proposed only an offer-in-                
          compromise.  Because no other collection alternatives were                  
          proposed, there were not less intrusive means for respondent to             
          consider.  We find that respondent balanced the need for                    






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