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enable the Commissioner to evaluate a taxpayer’s qualification
for collection alternatives or other relief. Picchiottino v.
Commissioner, T.C. Memo. 2004-231.
Petitioner had completed a Form 433-A and had turned it into
a revenue officer in 1998. Petitioner contends that respondent’s
Appeals officer failed to consider petitioner’s entire history as
she would not look at the 1998 form. Petitioner alleges that he
should not have to complete another Form 433-A as the Appeals
officer should have the 1998 form. However, the form completed
in 1998 does not represent current financial information, and as
petitioner did not give respondent current financial information,
it cannot be said that respondent acted arbitrarily or
capriciously in determining to proceed with collection. See id.;
Newstat v. Commissioner, T.C. Memo. 2004-208.
Petitioner also did not assert in the petition any spousal
defenses, any challenges to the appropriateness of the collection
actions, or any offers of collection alternatives other than an
offer-in-compromise that was going to be submitted at an
unspecified future date but was never submitted. See sec.
6330(c)(2)(A). The issues not raised in the pleadings are now
deemed conceded. Rule 331(b)(4). Therefore, we sustain
respondent’s determination regarding the proposed collection
action.
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Last modified: May 25, 2011