- 4 - 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 noPage: Previous 1 2 3 4 5 NextLast modified: November 10, 2007