- 18 -
(9th Cir. 1992); Weishan v. Commissioner, supra; see also Hansen
v. United States, 7 F.3d 137, 138 (9th Cir. 1993).
Petitioners have not alleged any irregularity in the
assessment procedure that would raise a question about the
validity of the assessments or the information contained in the
transcripts of account. See Davis v. Commissioner, 115 T.C. 35,
40-41 (2000); Mann v. Commissioner, T.C. Memo. 2002-48.
Accordingly, we hold that the Appeals 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 actions, or offer alternative means of collection.
These issues are now deemed conceded. Rule 331(b)(4). In the
absence of a justiciable issue for review, we conclude that
respondent is entitled to judgment as a matter of law sustaining
the notices of determination dated April 2, 2001.
B. Imposition of a Penalty Under Section 6673
We turn now to that part of respondent’s motion that moves
for the imposition of a penalty under section 6673.
As relevant herein, section 6673(a)(1) 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
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