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an offer-in-compromise); petitioners have also failed to raise
properly any other justiciable issue. See sec. 6330(c)(2)(A).
Such matters are now deemed conceded. See Rule 331(b)(4) (“Any
issue not raised in the assignments of error shall be deemed to
be conceded.”).
Conclusion
In view of the foregoing, we conclude that there is no
genuine issue of material fact that would necessitate a trial in
this case and that respondent is entitled to judgment as a matter
of law.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
An appropriate order and
decision will be entered.
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Last modified: May 25, 2011