Michael Schaper - Page 12




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               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 December 11, 2001.                                      
               In order to give effect to the foregoing,                              


                                             An appropriate order granting            
                                        respondent's motion and decision              
                                        for respondent will be entered.               



























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