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Court pursuant to section 6213(a). Consistent with section
6330(c)(2)(B), petitioner therefore was precluded from contesting
his liability for the underlying taxes before the Appeals Office.
Respondent's determination letter states that respondent
explained the effect of section 6330(c)(2)(B) to petitioner in a
letter dated July 6, 1999. Nevertheless, petitioner persisted in
arguing before the Appeals Office that he was not liable for the
underlying taxes on constitutional grounds.
While ignoring the proscription of section 6330(c)(2)(B),
petitioner likewise failed to assert before the Appeals Office
any of the claims enumerated under section 6330(c)(2)(A). In
particular, petitioner did not challenge the appropriateness of
the intended method of collection, offer an alternative means of
collection, or raise a spousal defense to collection as directed
under section 6330(c)(2)(A). Nor has he raised any such issue
before the Court.
Rule 331(b)(4) states that a petition for review of an
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. Rule 331(b)(5) states that
such a petition shall contain clear and concise lettered
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