Linh N. Nguyen - Page 8

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          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.                                    









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