- 14 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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