Janie M. Dixon and Joseph Dixon, Jr. - Page 10

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          by Ms. Dixon, set forth separately in petitioners’ pleadings,               
          will as indicated above be dealt with separately at a later date.           
          Otherwise, petitioners have not raised any challenges to the                
          appropriateness of the collection action or any collection                  
          alternatives.  As this Court has noted in earlier cases, Rule               
          331(b)(4) states that a petition for review of a collection                 
          action shall contain clear and concise assignments of each and              
          every error alleged to have been committed in the notice of                 
          determination and that any issue not raised in the assignments of           
          error shall be deemed conceded.  See Goza v. Commissioner, 114              
          T.C. 176, 183 (2000); see also Lunsford v. Commissioner, 117 T.C.           
          183, 185-186 (2001).                                                        
               The Court will grant respondent’s motion for partial summary           
          judgment.  Accordingly, except to the extent of any relief from             
          joint and several liability afforded to Ms. Dixon through future            
          proceedings, the decision ultimately entered in this case will              
          reflect that respondent may proceed with collection of                      
          petitioners’ tax liabilities.                                               
               To reflect the foregoing,                                              

                                                  An appropriate order                
                                             granting respondent’s motion             
                                             for partial summary judgment             
                                             will be issued.                          







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