Terrie Elaine Banks - Page 7

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          tax liability for 1995.  Accordingly, it follows that petitioner            
          is not entitled to challenge the existence or the amount of the             
          underlying tax liability for 1995 in this collection review                 
          proceeding.  See sec. 6330(c)(2)(B); Goza v. Commissioner, supra.           
          In this connection we note that petitioner’s reference to a                 
          notice of lien filed in 1996 for employment taxes is not related            
          to this proceeding and has no bearing on the collection                     
          proceeding at issue in this case.                                           
               Petitioner has not alleged any irregularity in the                     
          assessment procedure that would raise a question about the                  
          validity of the assessments or the information contained in the             
          transcript of account.  Moreover, petitioner has failed to raise            
          a spousal defense, make a valid challenge to the appropriateness            
          of respondent’s intended collection action, or offer alternative            
          means of collection.  These issues are now deemed conceded.  Rule           
          331(b)(4).  Under the circumstances, we conclude that respondent            
          is entitled to a judgment as a matter of law sustaining the                 
          notice of determination.                                                    
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   
               To give effect to the foregoing,                                       

                                        An appropriate order and                      
          decision will be entered for respondent.                                    







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