Michael A. Zapara and Gina A. Zapara - Page 34

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         does not consider issues or collection alternatives that are not             
         raised in the Appeals hearing.  Magana v. Commissioner, 118 T.C.             
         488, 493 (2002).                                                             
              B.  Offer in Compromise                                                 
              At some point during the Appeals hearing, Mr. Mather                    
         indicated that petitioners intended to submit an offer in                    
         compromise.  Nevertheless, petitioners failed to submit an offer             
         in compromise.  It appears that petitioners were not in full tax             
         compliance at the time of the Appeals hearing because they had               
         not filed their 1999 or 2000 Federal income tax return.                      
              C.  Other Challenges                                                    
              Petitioners raise no spousal defenses, other collection                 
         alternatives, or other challenges to the jeopardy levy.  Those               
         issues are deemed conceded.  See Rule 331(b)(4).                             
         VII.  Conclusion                                                             
              Under section 6330(c)(2)(B), petitioners are precluded from             
         challenging their underlying tax liabilities for 1993, 1994, and             
         1995.  Petitioners raised no challenges to their underlying tax              
         liabilities for 1997 and 1998 and, therefore, have conceded those            
         issues.  We remand this case to Appeals for purposes of                      

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