- 7 - issue but failed to commence an action in this Court. He has at no time alleged that he did not receive the deficiency notices, and there is no evidence in the record that any of the notices were returned as unclaimed or undeliverable. Accordingly, section 6330(c)(2)(B) precludes petitioner from disputing his underlying liabilities in this proceeding. Petitioner has not raised any challenges to the appropriateness of the collection action or any collection alternatives. A petition for review of a collection action must clearly specify the errors alleged to have been committed in the notice of determination. Any issues not raised in the assignments of error are deemed to be conceded by petitioner. Rule 331(b)(4); see Goza v. Commissioner, 114 T.C. 176, 183 (2000); see also Lunsford v. Commissioner, 117 T.C. 183, 185-186 (2001). The Court will grant respondent's motion for summary judgment. Accordingly, respondent may keep in place the notice of tax lien filed with respect to petitioner's tax liabilities. To reflect the foregoing, An appropriate order and decision will be entered in this case.Page: Previous 1 2 3 4 5 6 7 8
Last modified: May 25, 2011