- 11 - petitioner’s unpaid liability; see id.; see also Keene v. Commissioner, supra at 19-20; Kemper v. Commissioner, T.C. Memo. 2003-195. Petitioner has not alleged any irregularity in the assessment procedure that would raise a question about the validity of the assessments or the information contained in the Forms 4340 or transcripts of account. See Davis v. Commissioner, 115 T.C. 35, 41 (2000); Mann v. Commissioner, T.C. Memo. 2002-48. Appeals Officer Johansen stated in an affidavit that he verified that all legal and administrative requirements for levy had been met. He also considered whether the proposed levy balanced the need for efficient collection of taxes with the legitimate concern of the taxpayer that any collection action be no more intrusive than necessary. Petitioner has failed to raise a triable issue of fact concerning the Appeals officer’s review. Accordingly, we hold that the Appeals officer satisfied the verification requirement of section 6330(c)(1). Cf. Nicklaus v. Commissioner, 117 T.C. 117, 120-121 (2001). Petitioner has failed to raise a spousal defense, make a valid challenge to the appropriateness of respondent’s intended collection action, or offer alternative means of collection. These issues are now deemed conceded. See Rule 331(b)(4).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011