Mitra H. Salmassi - Page 4




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                                     Discussion                                       
               At the conclusion of the trial, we instructed petitioner as            
          to her briefing rights; i.e., to respond to respondent’s brief              
          and to raise any additional arguments she wished to raise.  Our             
          instruction reflected the requirements of Rule 151(e), addressing           
          the form and content of briefs.  Petitioner agreed to proceed in            
          that fashion.  In her brief, petitioner has argued only the                 
          hardship of complying with her tax obligations.  Therefore, we              
          deem petitioner to have abandoned other arguments supporting her            
          assignments of error.  See Mendes v. Commissioner, 121 T.C. 308,            
          312-313 (2003) (“If an argument is not pursued on brief, we may             
          conclude that it has been abandoned.”).                                     
               Among respondent’s proposed findings of fact are the                   
          following (we paraphrase):  During the course of the proceedings            
          leading to the determination, petitioner submitted an offer-in-             
          compromise as an alternative to respondent’s collection action              
          (viz, respondent filed a notice of Federal tax lien (NFTL)).  The           
          offer-in-compromise was accompanied by an Internal Revenue                  
          Service Form 433-A, Collection Information Statement for Wage               
          Earners and Self-Employed Individuals.  The Form 433-A shows an             
          investment account balance of $388,597 and a Charles Schwab                 
          account balance of $112,962.  The Appeals employee assigned to              
          petitioner’s case determined that petitioner had the ability to             
          pay her tax liabilities in full from accessible income in                   
          checking accounts and by liquidating assets.  Petitioner makes no           







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