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Thus, with respect to those issues enumerated in section
6330(c)(2)(A) and subject to review in collection proceedings for
abuse of discretion, petitioner has not raised any spousal
defenses, valid challenges to the appropriateness of the
collection action, or collection alternatives. As this Court has
noted in earlier cases, Rule 331(b)(4) states that a petition for
review of a collection action shall contain clear and concise
assignments of each and every error alleged to have been
committed in the notice of determination and that any issue not
raised in the assignments of error shall be deemed conceded. See
Lunsford v. Commissioner, 117 T.C. at 185-186; Goza v.
Commissioner, 114 T.C. 176, 183 (2000). For completeness, we
have addressed various points advanced by petitioner during the
administrative process, but the items listed in section
6330(c)(2)(A) were not pursued even during those proceedings.
Accordingly, the Court concludes that respondent’s determination
to proceed with collection of petitioner’s tax liabilities was
not an abuse of discretion. The Court will grant respondent’s
motion for summary judgment.6
6 To the extent that petitioner in his response to
respondent’s motion argues that summary judgment should be
granted sua sponte in his favor as the nonmoving party, any such
action would be unwarranted for the reasons discussed in the
text.
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Last modified: May 25, 2011