- 8 -
Weiss v. Commissioner, 221 F.2d 152, 156 (8th Cir. 1955), affg.
T.C. Memo. 1954-51; Schroeder v. Commissioner, T.C. Memo. 1986-
467.
We note that petitioner did not call his criminal defense
attorneys as witnesses. We infer that their testimony would not
have been favorable to petitioner. See Wichita Terminal Elevator
Co. v. Commissioner, 6 T.C. 1158, 1165 (1946), affd. 162 F.2d 513
(10th Cir. 1947).
Petitioner has 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. See Rule 331(b)(4).
We conclude that respondent correctly sustained the notice
of lien. In reaching all of our holdings herein, we have
considered all arguments made by the parties, and to the extent
not mentioned above, we find them to be irrelevant or without
merit.
To reflect the foregoing,
Decision will be entered
for respondent.
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