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rejected on the ground that he thought the total installment
payments required were excessive. The record provides no basis
for concluding that the balance due, as reflected in the
installment agreement, exceeded petitioner’s then-current balance
for the 1987 tax, penalties, and interest. To the contrary, the
limited evidence in the record suggests that the difference
between what petitioner believed his 1987 tax liability to be and
the amount shown on the proposed installment agreement was
attributable to the running of interest (which is running yet,
see section 6601(a)). On this record, we conclude that AO
Szalkowski did not abuse his discretion in determining that
collection action may proceed against petitioner.
C. Conclusion
Petitioner has raised no spousal defense and made no valid
challenge to the appropriateness of respondent’s intended
collection action. These issues are now deemed conceded. See
Rule 331(b)(4). We hold that respondent did not abuse his
discretion in sustaining the filing of a Federal tax lien with
respect to petitioner’s 1987 income tax.
To reflect the foregoing,
Decision will be
entered for respondent.
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Last modified: May 25, 2011