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assessments were properly made and that all other requirements of
applicable law and administrative procedure had been met.
Petitioner has not alleged any irregularity which would raise a
question about the information contained in the TXMODA
transcripts relied on by Ms. Smith. Accordingly, we conclude
there is no question that Ms. Smith satisfied the verification
requirement of section 6330(c)(1). See Kubon v. Commissioner,
supra.
Petitioner makes no other arguments against the validity of
the notice of determination. In particular, petitioner fails to
make a valid challenge to the appropriateness of respondent’s
intended collection actions, raise a spousal defense, or offer
alternative means of collection. See sec. 6330(c)(2)(A). We
conclude that respondent did not abuse his discretion in
determining that collection should proceed and that respondent is
entitled to judgment as a matter of law.
Section 6673(a)(1) authorizes the Court to require a
taxpayer to pay to the United States a penalty in an amount not
to exceed $25,000 whenever it appears to the Court that the
proceedings have been instituted or maintained primarily for
delay or that the taxpayer’s position in the proceeding is
frivolous or groundless. Sec. 6673(a)(1)(A) and (B). Respondent
does not ask the Court to impose a penalty on petitioner under
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Last modified: November 10, 2007