- 8 - 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.Page: Previous 1 2 3 4 5 6 7 8
Last modified: May 25, 2011