Orlun K. Jones - Page 5




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          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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