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salary as he is the sole income earner supporting his wife and
children. Where the validity of the underlying tax liability is
not properly in issue, we review respondent’s determination for
an abuse of discretion. Sego v. Commissioner, 114 T.C. 604, 610
(2000).
Based on petitioners’ late-filed 1996 tax return, respondent
abated a portion of petitioners’ income tax, additions to tax,
and interest for 1996. As a result of the hearing, respondent
further abated a portion of the section 6651(a)(2) addition to
tax and interest for 1996 and 1997.
Petitioners simply do not want to pay the additions to tax
and interest associated with their failure to timely file and
failure to timely pay. Petitioners did not submit an offer-in-
compromise or an installment agreement to respondent. Respondent
gave due consideration to the collection alternatives raised by
petitioners and accepted them in part (i.e., respondent
determined petitioners were entitled to a partial abatement of
the assessed section 6651(a)(2) addition to tax and the
associated interest for 1996 and 1997). We conclude that
respondent’s determination was reasonable.
Petitioners have failed to raise a spousal defense or make a
valid challenge to the appropriateness of respondent’s intended
collection action. These issues are now deemed conceded. See
Rule 331(b)(4). Accordingly, we conclude that respondent did not
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