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defenses, valid challenges to the appropriateness of the
collection action, or collection alternatives. As this Court has
noted in earlier cases, Rule 331(b)(4) states that a petition for
review of a collection action shall contain clear and concise
assignments of each and every error alleged to have been
committed in the notice of determination and that any issue not
raised in the assignments of error shall be deemed conceded. See
Lunsford v. Commissioner, 117 T.C. at 185-186; Goza v.
Commissioner, 114 T.C. 176, 183 (2000). For completeness, we
have addressed various points advanced by petitioner during the
administrative process or before us in Phoenix, but no
meritorious items were pursued even in those proceedings.
Accordingly, the Court concludes that respondent’s determination
to proceed with collection of petitioner’s tax liabilities was
not an abuse of discretion.
II. Section 6673 Penalty
Section 6673(a)(1) authorizes the Court to require the
taxpayer to pay a penalty not in excess of $25,000 when it
appears to the Court that, inter alia, proceedings have been
instituted or maintained by the taxpayer primarily for delay or
that the taxpayer’s position in such proceeding is frivolous or
groundless. In Pierson v. Commissioner, 115 T.C. 576, 581
(2000), the Court warned that taxpayers abusing the protections
afforded by sections 6320 and 6330 through the bringing of
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