- 13 - 1996, 1998, or 1999, raised material issues pertaining to any of those matters enumerated in section 6330(c)(2)(A) and subject to review for abuse of discretion. These items include spousal defenses, collection alternatives, and other valid challenges to the appropriateness of the collection action. Id. The record does not reflect that petitioner has at any time pursued a spousal defense. As to collection alternatives, there was some discussion at the hearing on respondent’s motion concerning a series of $65 payments made by petitioner at some time between 1999 and 2002. A review of transcripts of petitioner’s accounts revealed that these payments had been properly credited, and petitioner did not suggest that he had proposed or was currently seeking an installment agreement or other collection alternative to satisfy his outstanding liabilities for the period before us. Nor is there any indication that petitioner has otherwise challenged the appropriateness of the collection action within the meaning of section 6330(c)(2)(A). Given that matters not properly raised or preserved in collection proceedings are typically deemed conceded, see Rule 331(b)(4); Magana v. Commissioner, 118 T.C. 488, 493-494 (2002); Lunsford v. Commissioner, 117 T.C. 183, 185-186 (2001); Goza v. Commissioner, 114 T.C. 176, 183 (2000), we conclude that petitioner has not advanced any issues of material fact withPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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