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basis of: (1) Petitioner’s financial information, (2)
petitioner’s having taken no significant voluntary action (as
suggested) towards resolving his tax situation, and (3)
petitioner’s having paid only $111 (via withholding) and $4,000
(via a 1999 estimated tax payment) towards assessed taxes of
$184,733 for 1997 through 2003, respondent determined that
petitioner did not submit a viable collection alternative.
At trial, the Court asked petitioner several times whether
he wanted to put on any evidence or had any evidence to submit
regarding respondent’s determination. Petitioner did not take
advantage of any of the repeated opportunities the Court
presented to him.
Petitioner has failed to raise a spousal defense, make a
valid challenge to the appropriateness of respondent’s intended
collection action, or offer a viable alternative means of
collection. These issues are now deemed conceded. See Rule
331(b)(4). Accordingly, we conclude that respondent did not
abuse his discretion, and we sustain respondent’s determination
to proceed with collection.
II. Section 6673(a)
Section 6673(a)(1) authorizes this Court to require a
taxpayer to pay to the United States a penalty not to exceed
$25,000 if the taxpayer took frivolous positions in the
proceedings or instituted the proceedings primarily for delay. A
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