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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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