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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
2(...continued)
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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