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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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Last modified: May 25, 2011