Stephen and Patricia Lindsey - Page 10




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          against a taxpayer).                                                        
              Petitioners have not alleged any irregularity in the                   
          assessment process that would raise a question about the validity           
          of the assessments or the information contained in the                      
          transcripts of account or the Forms 4340.  Id.; Mann v.                     
          Commissioner, T.C. Memo. 2002-48.  Accordingly, we hold that the            
          settlement officer satisfied the verification requirement of                
          section 6330(c)(1).  Cf. Nicklaus v. Commissioner, 117 T.C. 117,            
          120-121 (2001).                                                             
          Petitioners have 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 valid issue for review, we conclude that there is no           
          dispute as to a material fact and that respondent is entitled to            
          judgment as a matter of law sustaining the notice of                        
          determination dated August 9, 2000.                                         
               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               






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