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Petitioner, in his petition, generally alleged that he
disagrees with the amount of the tax and that he would like to
pay under an installment agreement. The petition does not
contain specific assignments of error or any statements of
alleged facts. See Rule 331(b)(4) and (5). Petitioner also
failed to set forth facts showing that there is a material or
specific question regarding the amount of his underlying
liability. In addition, the Appeals officer considered
petitioner for an offer-in-compromise but determined he was not
eligible, and petitioner does not contest that determination.
Petitioner did not contend that the Appeals officer failed to
comply with any other applicable law, and he did not raise any
other relevant issue such as spousal defenses, challenges to the
appropriateness of collection actions, or other collection
alternatives. Accordingly, there exists no issue of material
fact in this case, and respondent is entitled to summary
judgment. Respondent is therefore entitled to proceed with
collection activity.
To reflect the foregoing,
An appropriate order and
decision will be entered for
respondent.
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Last modified: May 25, 2011