- 9 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10
Last modified: May 25, 2011