James L. Geary and Carol O. Geary - Page 10

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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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