Gloria M. Stark - Page 9

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          judgment), affd. without published opinion 993 F.2d 1533 (2d Cir.           
               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.                              

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