Michael Norton - Page 8

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          Weiss v. Commissioner, 221 F.2d 152, 156 (8th Cir. 1955), affg.             
          T.C. Memo. 1954-51; Schroeder v. Commissioner, T.C. Memo. 1986-             
               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               
               To reflect the foregoing,                                              

                                                  Decision will be entered            
                                             for respondent.                          

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