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Commissioner, T.C. Memo. 2002-106; Weishan v. Commissioner, T.C.
Memo. 2002-88; Lindsey v. Commissioner, T.C. Memo. 2002-87;
Tolotti v. Commissioner, T.C. Memo. 2002-86; Duffield v.
Commissioner, T.C. Memo. 2002-53; Kuglin v. Commissioner, T.C.
Memo. 2002-51.
Petitioner has not alleged any irregularity in the
assessment procedure that would raise a question about the
validity of the assessments or the information contained in the
transcripts of account. Davis v. Commissioner, 115 T.C. 35, 41
(2000); Mann v. Commissioner, T.C. Memo. 2002-48. Accordingly,
we hold that the verification requirement of section 6330(c)(1)
has been satisfied. Cf. Nicklaus v. Commissioner, 117 T.C. 117,
120-121 (2001).
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 did not abuse his
discretion and sustain respondent’s determination.
Section 6673(a)(1) authorizes this Court to require a
taxpayer to pay to the United States a penalty not to exceed
$25,000 if the taxpayer took frivolous positions in the
proceedings or instituted the proceedings primarily for delay.
In Pierson v. Commissioner, 115 T.C. 576, 581 (2000), we issued
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