- 10 - The foregoing presumptions, coupled with the factors previously discussed, oblige us to conclude that petitioners received the July 29, 2004 notice of deficiency. As a consequence, section 6330(c)(2)(B) bars petitioners from challenging the existence or amount of their outstanding liability for 2002. See Bailey v. Commissioner, T.C. Memo. 2005- 241. Conclusion Petitioners have failed to make a valid challenge to the appropriateness of respondent’s intended collection action, offer an alternative means of collection, or raise a spousal defense. See Rule 331(b)(4) (“Any issue not raised in the assignments of error shall be deemed to be conceded.”). In the absence of a valid issue for review, we conclude that respondent is entitled to judgment as a matter of law sustaining the October 4, 2006 notice of determination. Accordingly, we shall grant respondent’s Motion For Summary Judgment, as supplemented, and thereby sustain the determination of the Appeals Office permitting respondent to proceed with collection for 2002. To give effect to the foregoing, An order granting respondent’s Motion For Summary Judgment, as supplemented, and decision for respondent will be entered.Page: Previous 1 2 3 4 5 6 7 8 9 10 11Last modified: November 10, 2007