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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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Last modified: May 25, 2011