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The evidence does not establish that petitioner is entitled
to abatement of interest in amounts greater than those abated or
conceded by respondent. We conclude that respondent did not
abuse his discretion in not abating interest for 1987 or 1989 for
any amounts greater than those he abated or conceded.
C. Remaining Section 6330 Issues
Petitioner stated that he wanted to make an offer-in-
compromise at the section 6330 hearing; however, petitioner did
not follow through. Appeals Officer Cayenne gave petitioner the
appropriate forms to file an offer-in-compromise, but petitioner
did not submit an offer-in-compromise.
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).
Accordingly, we conclude that respondent’s determination to
proceed with collection with respect to petitioner’s 1987 and
1989 tax years was not an abuse of discretion.
No motions remain outstanding. In reaching all of our
9(...continued)
interest. In his reply brief, respondent proffered that as of
the date of the filing of his reply brief, respondent had abated
the interest associated with petitioner’s withholding credit for
1989. The record does not contain evidence that the
aforementioned interest has been abated; therefore, we will
incorporate respondent’s concession of this issue into our
decision.
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