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satisfy the verification requirements of section 6330(c)(1). See
Roberts v. Commissioner, 118 T.C. 365, 371 n.10 (2002), affd. 329
F.3d 1224 (11th Cir. 2003); Nestor v. Commissioner, 118 T.C. 162,
166 (2002); Lunsford v. Commissioner, 117 T.C. 183 (2001).
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
Form 4340. Moreover, 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. Rule
331(b)(4).
The record reflects that respondent has complied with all
applicable laws and administrative procedures in this case.
Consistent with the preceding discussion, it follows that
respondent is entitled to judgment as a matter of law sustaining
respondent’s determination to proceed with collection.
To reflect the foregoing,
An Order and Decision will
be entered granting respondent’s
Motion for Summary Judgment.
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Last modified: May 25, 2011