- 6 - 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.Page: Previous 1 2 3 4 5 6 7
Last modified: May 25, 2011