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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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