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administrative determination filed pursuant to section 6330 shall
contain clear and concise assignments of each and every error
which the petitioner alleges to have been committed in the levy
determination and any issue not raised in the assignments of
error shall be deemed to be conceded. Additionally, Rule
331(b)(5) states that such a petition shall contain clear and
concise lettered statements of the facts on which the petitioner
bases each assignment of error.
In the petition, petitioner only makes the broad assertion
that he does not have to pay taxes. There are neither specific
assignments of error nor any statement of facts. Petitioner did
not set forth in the petition any specific issues or factual
basis for his disagreement with the tax liabilities reported on
his 2001 return. Consequently, there is no genuine issue of
material fact, and respondent is entitled to summary judgment
with respect to the 2001 tax year. See Poindexter v.
Commissioner, 122 T.C. 280 (2004), affd. 132 Fed. Appx. 919 (2d
Cir. 2005).
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Last modified: May 25, 2011