- 9 -
supra. Therefore, we conclude that respondent did not err in
denying petitioner a credit for the alleged overpayments. See
Landry v. Commissioner, supra.
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.
We therefore sustain respondent’s determination to proceed
with collection of petitioner’s 1994, 1995, 1996, 1998, and 1999
income tax liabilities.
In reaching all of our holdings herein, we have considered
all the parties’ arguments, and, to the extent not herein
discussed, we find them to be irrelevant or without merit.
To reflect the foregoing,
Decision will be entered
for respondent.
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