Robert E. Crandall - Page 19

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          abuse of discretion, petitioner has not raised any spousal                  
          defenses, valid challenges to the appropriateness of the                    
          collection action, or collection alternatives.  As this Court has           
          noted in earlier cases, Rule 331(b)(4) states that a petition for           
          review of a collection action shall contain clear and concise               
          assignments of each and every error alleged to have been                    
          committed in the notice of determination and that any issue not             
          raised in the assignments of error shall be deemed conceded.  See           
          Lunsford v. Commissioner, 117 T.C. at 185-186; Goza v.                      
          Commissioner, 114 T.C. 176, 183 (2000).  For completeness, we               
          have addressed various points advanced by petitioner during the             
          administrative process and this litigation, but the items listed            
          in section 6330(c)(2)(A) were not pursued in any proceedings.               
          Accordingly, the Court concludes that respondent’s determination            
          to proceed with collection of petitioner’s tax liabilities was              
          not an abuse of discretion.                                                 
          II.  Section 6673 Penalty                                                   
               Section 6673(a)(1) authorizes the Court to require the                 
          taxpayer to pay a penalty not in excess of $25,000 when it                  
          appears to the Court that, inter alia, proceedings have been                
          instituted or maintained by the taxpayer primarily for delay or             
          that the taxpayer’s position in such proceeding is frivolous or             
          groundless.  In Pierson v. Commissioner, 115 T.C. at 581, we                
          warned that taxpayers abusing the protections afforded by                   

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