Early Robertson, Jr. - Page 13

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          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 with                

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