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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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Last modified: May 25, 2011