- 11 -
incorrect. See also Montgomery v. Commissioner, supra at 19
(Marvel, J., concurring). We conclude that respondent’s second
ground (together with his third ground, discussed next) justifies
summary judgment.
IV. Petitioner Has Failed To Aver Facts Showing Any Other Error
in the Determination
Although petitioner avers errors in the assessment
procedures and in other procedures, and improper execution of
levies, he sets forth no factual basis for those claims. Indeed,
respondent has yet to make any levies with respect to the
assessments. Except as we have discussed with respect to the
Appeals officer’s refusal to consider the accuracy of the
assessments, we see no error in the determination.
V. Conclusion
Petitioner has failed to put before us grounds on which we
could find that the Appeals officer erred in the determination.
On that basis, respondent is entitled to summary disposition in
his favor.
To reflect the foregoing,
An appropriate order and
decision will be entered for
respondent.
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Last modified: May 25, 2011