George E. Harp - Page 9




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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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