Stanley Howard - Page 5




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               Petitioner’s sole allegation of error is that the Appeals              
          officer abused her discretion by failing to obtain proper                   
          verification of the liability from the Secretary as required by             
          section 6330(c)(1).2  The Appeals officer relied on the computer            
          transcript of account to verify petitioner’s tax liability.                 
          Respondent argues that in the absence of any evidence of an                 
          irregularity in the assessment, reliance upon the transcript of             
          account as verification of the liability is sufficient to satisfy           
          the requirements of section 6330(c)(1).  We agree with                      
          respondent.                                                                 
               Section 6331(a) provides that, if any person liable to pay             
          any tax neglects or refuses to pay the tax within 10 days after             
          notice and demand for payment, the Secretary may collect the tax            
          by levy upon the taxpayer’s property.  Section 6331(d) provides             
          that the Secretary must provide the taxpayer with notice,                   
          including notice of the administrative appeals available to the             
          taxpayer, before proceeding with collection by such a levy.                 
               In 1998, Congress enacted section 6330 to provide additional           
          procedural protections for taxpayers in tax collection matters              


               2  Any other issues raised by petitioner at the                        
          administrative level are deemed conceded because petitioner did             
          not pursue them at trial and did not file a posttrial brief as              
          required by the Court’s rules.  See Rule 151(a); Remuzzi v.                 
          Commissioner, T.C. Memo. 1988-8, (issue not addressed by the                
          taxpayers on brief deemed conceded) affd. without published                 
          opinion 867 F.2d 609 (4th Cir. 1989).                                       






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