James G. Gilligan - Page 11

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          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).                  









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