Brandon Christopher Merriweather - Page 8

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            ways that count.”  This, however, does not entitle him to claim a                           
            dependency exemption for Calesa, head of household status, or an                            
            EIC for 1997.                                                                               
                  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).                                      
            Accordingly, we sustain respondent’s determination to proceed                               
            with collection with respect to petitioner’s 1997 tax year.                                 
                  To reflect the foregoing,                                                             
                                                             Decision will be entered                   
                                                       for respondent.                                  

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