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Roberts v. Commissioner, 118 T.C. 365, 371 (2002).4 Respondent,
for a number of years, has been making a transition in his
assessment procedure from the use of a manually prepared Form 23C
to the use of the RACS report. Id.
Petitioner has not alleged any irregularity in the
assessment procedure that would raise a question about the
validity of the assessments or the information contained in the
transcripts of account. Davis v. Commissioner, 115 T.C. 35, 41
(2000); Mann v. Commissioner, T.C. Memo. 2002-48. Accordingly,
we hold that the Appeals officer satisfied the verification
requirement of section 6330(c)(1). Cf. Nicklaus v. Commissioner,
117 T.C. 117, 120-121 (2001).
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).
On brief, petitioner also argues that he did not receive a
section 6330 hearing because he was not allowed to have a court
reporter, to call witnesses, or to cross-examine witnesses at the
section 6330 hearing. Generally, we do not consider issues that
4 We note that the taxpayer in Roberts v. Commissioner, 118
T.C. 365 (2002), was Thomas W. Roberts--petitioner’s
representative prior to trial.
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