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underlying liability in this proceeding. Goza v. Commissioner,
114 T.C. 176 (2000). Furthermore, petitioner has not raised an
issue of a spousal defense, made a challenge to the
appropriateness of respondent’s intended collection action, or
offered alternative means of collection. These issues are now
deemed conceded. Rule 331(b)(4). Under these circumstances, we
conclude that respondent is entitled to judgment as a matter of
law sustaining the notice of determination.
An appropriate order and decision will be entered that
respondent may proceed with collection action as determined in
the Notice of Determination Concerning Collection Action(s) Under
Section 6320 and/or 6330 for the taxable years 1992 through 1997,
dated April 7, 2003.
An appropriate order and
decision will be entered.
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