Peggy A. Farley - Page 10

                                       - 10 -                                         
          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.                





















Page:  Previous  1  2  3  4  5  6  7  8  9  10  

Last modified: May 25, 2011