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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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Last modified: November 10, 2007