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In sum, petitioner is statutorily barred from challenging
the existence or amount of his income tax liability for 1993 in
this proceeding. Petitioner has failed to raise a spousal
defense, make a valid challenge to the appropriateness of
respondent’s intended collection action, or offer alternative
means of collection. These issues are now deemed conceded. Rule
331(b)(4). Accordingly, in the absence of a valid issue for
review, we conclude that respondent is entitled to judgment as a
matter of law sustaining the notice of determination dated March
15, 2001.
To order to give effect to the foregoing,
An order granting respondent’s
Motion For Summary Judgment and
decision for respondent will be
entered.
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