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6203, give notice to each person liable for the unpaid
tax, stating the amount and demanding payment thereof.
* * *
The record in this case includes notices CP 504, dated
June 4, 2001, addressed to petitioner and his wife for each of
the years in question. Petitioner does not deny that he received
such notices. These notices informed petitioner that he owed
taxes for 1992 to 1997 and 1999, and included a demand for the
immediate payment of the amounts due. Such notices constitute
notice and demand for payment within the meaning of section
6303(a). See, e.g., Hughes v. United States, 953 F.2d 531, 536
(9th Cir. 1992); Weishan v. Commissioner, supra.
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). Under the
circumstances, we conclude that respondent is entitled to
judgment as a matter of law sustaining the notice of
determination dated November 21, 2001.
As a final matter, 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
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