- 11 -
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 Lunsford v. Commissioner, 117 T.C. 183,
185-186 (2001); Goza v. Commissioner, 114 T.C. 176, 183 (2000).
Accordingly, having considered those matters set forth in
petitioners’ pleadings, the Court concludes that respondent’s
determination to proceed with collection was not an abuse of
discretion. Respondent’s motion for summary judgment will be
granted.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011