- 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.
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