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petitioner’s failure to respond to the Court’s Orders, we
conclude that petitioner has abandoned the issue.
Petitioner failed to raise a spousal defense, make a valid
challenge to the appropriateness of respondent's intended
collection action, or offer alternative means of collection.
These issues are now deemed conceded. Rule 331(b)(4). From the
entire record in this case, we conclude that the Appeals Office
did not abuse its discretion in determining that it was
appropriate to proceed with collection of petitioner's tax
liabilities for 1998 and 1999.
As a final matter, we mention section 6673(a)(1), which
authorizes the Tax Court to require a taxpayer to pay to the
United States a penalty not in excess of $25,000 whenever it
appears that 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. The Court has
indicated its willingness to impose such penalties in collection
review cases. Pierson v. Commissioner, 115 T.C. 576 (2000).
Although we do not impose a penalty on petitioner pursuant to
section 6673(a)(1) at this time, we admonish petitioner that the
Court will consider imposing such a penalty should he return to
the Court in the future and advance arguments similar to those
that we have identified as frivolous.
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