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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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