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validity of the assessments or the information contained in the
transcripts of account. See Davis v. Commissioner, 115 T.C. 35,
40-41 (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). In the
absence of a justiciable issue for review, we conclude that
respondent is entitled to judgment as a matter of law sustaining
the notice of determination dated May 9, 2001.
Finally, we mention section 6673(a)(1), which authorizes the
Tax Court to require a taxpayer to pay to the United States a
penalty not in excess of $25,000 whenever it appears that
proceedings have been instituted or maintained by the taxpayer
primarily for delay or that the taxpayer's position in such
proceeding is frivolous or groundless. The Court has indicated
its willingness to impose such penalties in collection review
cases. Pierson v. Commissioner, 115 T.C. 576 (2000). Although
we will not impose a penalty on petitioner pursuant to section
6673(a)(1) in the present case, we admonish petitioner that the
Court shall consider imposing such a penalty should he return to
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