-7-
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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