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Memo. 2002-51. Moreover, Mr. Luhmann’s declaration verified that
the notice and demand for tax was sent to petitioner within 60
days of the assessment.
Accordingly, we hold both that respondent was in compliance
with all legal and administrative procedures with respect to the
CDP action, and that petitioner conceded all other issues by not
providing a clear and concise assignment of error.
II. CDP Not More Intrusive Than Necessary
Rule 331(b)(4) requires that a petition must contain clear
and concise assignments of each and every error that the taxpayer
alleges to have been committed in the notice of determination,
including whether the proposed collection action is more
intrusive than necessary. Any issue not otherwise raised in
these assignments of error is deemed conceded. Id. Petitioner
did not raise any issue with respect to whether or not the
proposed collection action was more intrusive than necessary in
his petition. Accordingly, and pursuant to Rule 331(b)(4), we
hold that petitioner conceded this issue.
III. Concession of Issues at CDP Hearing
Section 6330(c)(2)(A) provides:
(A) In general.--The person may raise at the
hearing any relevant issue relating to the unpaid tax
or the proposed levy, including--
(i) appropriate spousal defenses;
(ii) challenges to the appropriateness of
collection actions; and
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