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other issues enumerated in section 6330(c)(2)(A) and subject to
review in collection proceedings for abuse of discretion,
petitioner has not raised any spousal defenses or valid
challenges to the appropriateness of the collection action. 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, the
Court concludes that respondent’s determination to proceed with
collection of petitioner’s tax liabilities was not an abuse of
discretion.
To reflect the foregoing,
An appropriate order
granting respondent’s motion
and decision for respondent
will be entered.
3(...continued)
filing requirements as a prerequisite to approval of an
installment agreement. 2 Administration, Internal Revenue Manual
(CCH) sec. 5.14.1.4.1, at 17,510 (July 1, 2002).
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Last modified: May 25, 2011