Merry J. Chandler - Page 3

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                                  FINDINGS OF FACT                                    
               The parties filed a stipulation of facts, which, with                  
          accompanying exhibits, is incorporated herein by reference.                 
               Petitioner resided in Bowie, Maryland, at the time the                 
          petition was filed.                                                         
               On July 25, 2000, respondent issued to petitioner a Final              
          Notice - Notice of Intent To Levy and Notice of Your Right to a             
          Hearing (the notice), which sets forth the unpaid liabilities and           
          describes respondent’s intent to levy on petitioner’s property to           
          collect those liabilities.  On August 7, 2000, petitioner timely            
          filed a Request for a Collection Due Process Hearing (the                   
          request).  On June 26, 2001, the request was assigned to Appeals            
          Officer Francis McNichol, Jr.  Mr. McNichol maintained a written            

          the conclusion of the trial, the Court instructed petitioner that           
          she was required to file briefs.  In particular, we instructed              
          her that, as to any argument she wished to make, she should state           
          in her brief the facts she wished the Court to find and then,               
          based on those facts, argue her case to the Court.  Petitioner              
          filed both an opening brief and an answering brief.  Although in            
          her opening brief petitioner proposes facts and makes an argument           
          with respect to the issue of whether she requested a face-to-face           
          interview with Appeals Officer McNichols, she neither proposes              
          facts nor makes any argument with respect to her claims that she            
          paid in full her liability for 1997 or that Appeals Officer                 
          McNichols failed to allow her reasonable time to submit an                  
          amended offer in compromise.  If an argument is not pursued on              
          brief, we may conclude that it has been abandoned.  E.g., Mendes            
          v. Commissioner, 121 T.C. 308, 312-313 (2003).  Because of our              
          instruction to petitioner concerning her brief and her pursuit on           
          brief exclusively of the face-to-face interview issue, we                   
          conclude that she has abandoned her other two claims, and we need           
          not discuss them.                                                           

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