- 7 - 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.Page: Previous 1 2 3 4 5 6 7 8 Next
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