Stuart M. Smith, Jr. - Page 7




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          discussion.  Petitioner did not provide any evidence that the               
          amount of his tax liability for 1985, as determined by                      
          respondent, is incorrect.  Given that petitioner set forth in his           
          petition no allegation that respondent abused his discretion,               
          that petitioner has not claimed that the proposed method of                 
          collection is inappropriate, that petitioner has not offered any            
          alternative means of collection, and that petitioner has raised             
          no spousal defenses, we hold for respondent.  See Lunsford v.               
          Commissioner, 117 T.C. 183 (2001); Smith v. Commissioner, T.C.              
          Memo. 2002-59.  To reflect the foregoing,                                   


                                                  Decision will be entered            
                                             for respondent.                          

























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