- 19 -
criminal and civil penalties, respectively, against IRS personnel
in enumerated circumstances, are not within the jurisdiction of
this Court.
Thus, with respect to those issues enumerated in section
6330(c)(2)(A) and subject to review in collection proceedings for
abuse of discretion, petitioner has not raised any spousal
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 and this litigation, but the items listed
in section 6330(c)(2)(A) were not pursued in any 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
Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 NextLast modified: May 25, 2011