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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.
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