- 9 - judgment), affd. without published opinion 993 F.2d 1533 (2d Cir. 1993). The petition does not explicitly raise a request for equitable relief under section 6015(f). To the extent that the petition might be construed to raise such a claim inferentially, we hold that petitioner is not entitled to such relief, having failed to file a joint Federal income tax return for any year at issue. See Raymond v. Commissioner, 119 T.C. 191, 195 (2002). Petitioner has failed to make a valid challenge to the appropriateness of respondent’s intended collection action. She has raised no issue in this proceeding regarding any offer of an alternative means of collection.4 These issues are now deemed conceded. Rule 331(b)(4). Accordingly, we conclude that respondent is entitled to summary judgment as a matter of law. To reflect the foregoing, An appropriate order and decision will be entered granting respondent’s motion for summary judgment. 4 After the administrative hearing, petitioner submitted an offer in compromise to respondent but withdrew it before respondent issued the notice of determination.Page: Previous 1 2 3 4 5 6 7 8 9
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