Robert Lee, Jr. - Page 8

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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           
               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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