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issues not otherwise raised in these assignments of error are
deemed conceded. Id.
In his underlying petition, petitioner made no such
assignments of error with respect to respondent’s determination.
The petition only contained statements that petitioner objected
to the determination on the basis that the Federal tax system was
both voluntary and inherently unfair. Accordingly, pursuant to
Rule 331(b)(4), the Court holds that petitioner conceded all
other issues relevant to the notice of determination.
We finally consider whether respondent has verified,
pursuant to section 6330(c)(1), that all of the requirements of
applicable law or administrative procedure were satisfied with
respect to the CDP action. The underlying record contains the
declaration of Monty Luhmann (Mr. Luhmann), a settlement officer
with respondent’s Office of Appeals, in which Mr. Luhmann
attested to the underlying tax and penalty assessments made
against petitioner for the years 1997, 1998, and 1999. Mr.
Luhmann’s attestation was based upon his review of respondent’s
transcripts generated by its Integrated Data Retrieval System.
These transcripts contain petitioner’s name, Social Security
number, the amounts assessed, and gross and taxable income. The
Court has held that the use of records containing such
information by an Appeals officer is not an abuse of discretion
when used to verify an assessment. Kuglin v. Commissioner, T.C.
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Last modified: May 25, 2011