-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.Page: Previous 1 2 3 4 5 6 7
Last modified: May 25, 2011