- 9 - Conclusion Petitioner has not alleged any irregularity in the assessment procedure that would raise a question about the validity of the assessments or the information contained in the transcript of account. Moreover, petitioner has failed to 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. Rule 331(b)(4). Under the circumstances, we conclude that respondent is entitled to judgment as a matter of law sustaining the notice of determination. To reflect the foregoing, An Order granting respondent’s Motion For Summary Judgment and Decision will be entered.Page: Previous 1 2 3 4 5 6 7 8 9
Last modified: May 25, 2011