Randy R. Romano - Page 6

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          administrative determination filed pursuant to section 6330 shall           
          contain clear and concise assignments of each and every error               
          which the petitioner alleges to have been committed in the levy             
          determination and any issue not raised in the assignments of                
          error shall be deemed to be conceded.  Additionally, Rule                   
          331(b)(5) states that such a petition shall contain clear and               
          concise lettered statements of the facts on which the petitioner            
          bases each assignment of error.                                             

               In the petition, petitioner only makes the broad assertion             
          that he does not have to pay taxes.  There are neither specific             
          assignments of error nor any statement of facts.  Petitioner did            
          not set forth in the petition any specific issues or factual                
          basis for his disagreement with the tax liabilities reported on             
          his 2001 return.  Consequently, there is no genuine issue of                
          material fact, and respondent is entitled to summary judgment               
          with respect to the 2001 tax year.  See Poindexter v.                       
          Commissioner, 122 T.C. 280 (2004), affd. 132 Fed. Appx. 919 (2d             
          Cir. 2005).                                                                 















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