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statement in his petition that he was contesting the validity of
all the tax liabilities at issue in this case, petitioner did not
argue at trial or in his posttrial briefs that respondent’s
determination for 1999 was incorrect. Petitioner also failed to
introduce any evidence at trial regarding his 1999 tax liability.
Accordingly, we conclude that petitioner has abandoned his
challenge to his 1999 tax liability. See, e.g., Bradley v.
Commissioner, 100 T.C. 367, 370 (1993); Rybak v. Commissioner, 91
T.C. 524, 566 n.19 (1988).
II. Petitioner’s Challenge to Respondent’s Determination To
Proceed With the Collection Action
In addition to his argument that respondent’s proposed
collection action is overly intrusive because the assessments of
petitioner’s tax liabilities are incorrect, petitioner argues
that he should have been allowed to submit an offer-in-
compromise.8 We review respondent’s determination to proceed
with collection for abuse of discretion. Sego v. Commissioner,
114 T.C . at 610.
8Even if we had concluded that petitioner could challenge
the validity of his 1995 and 1996 tax liabilities in this
proceeding, petitioner would still not have prevailed. The
documentation in the record upon which petitioner relied to
substantiate his Schedule C expenses was not sufficient to prove
that the expenses were deductible. Petitioner paid most of the
expenses in connection with his efforts to start several new
businesses during 1995 and 1996. Startup expenses resulting in
an active trade or business generally are not deductible for a
year earlier than the one in which such business begins. Sec.
195. Petitioner’s car expenses also were not deductible because
petitioner failed to satisfy the substantiation requirement of
sec. 274(d).
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