- 9 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10
Last modified: May 25, 2011