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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.
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Last modified: May 25, 2011