- 5 - T.C. 604, 610 (2000). Accordingly, we review the Appeals officer’s determinations for abuse of discretion. See id. Petitioner contends that on February 8, 2005 (the same date he submitted a Form 12153 requesting a hearing with respect to the Federal tax lien filing), he requested audit reconsideration. Petitioner contends that he repeatedly requested that the Appeals officer’s determination should await the results of the requested audit reconsideration, so that petitioner could determine what collection alternative, if any, might be appropriate. Petitioner contends that the Appeals officer abused his discretion by issuing his determinations before the request for audit reconsideration had been acted upon.3 We disagree. Pursuant to the applicable regulations, the Appeals Office shall “attempt to conduct a * * * [section 6330 hearing] and issue a Notice of Determination as expeditiously as possible under the circumstances.” Sec. 301.6330-1(e)(3), Q&A- E9, Proced. & Admin. Regs.; see Murphy v. Commissioner, 125 T.C. 301, 322 (2005) (“‘there is neither a requirement nor reason that the Appeals officer wait a certain amount of time before rendering his determination as to a proposed levy’” (quoting Clawson v. Commissioner, T.C. Memo. 2004-106)), affd. 469 F.3d 27 3 Petitioner contends that on Feb. 15, 2007, he received notification from the IRS of audit reconsideration and has since submitted information and returns to the audit reconsideration agent.Page: Previous 1 2 3 4 5 6 7 NextLast modified: November 10, 2007