Raymond Wright - Page 14




                                       - 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

Last modified: May 25, 2011