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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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Last modified: May 25, 2011