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The disagreements expressed by petitioner for 1999 and 2000
in her petition relate to the deductibility of certain claimed
expenses on Schedules A and C and the applicability of penalties.
Because petitioner self-assessed her taxes for all years in
issue, no statutory notice of deficiency was issued. See sec.
6201(a)(1). Petitioner therefore could have challenged the
existence or amount of the underlying tax liabilities during the
Appeals Office hearing. Petitioner, however, did not do so, and
she is accordingly precluded from challenging the underlying tax
liabilities in this proceeding. Sec. 301.6320-1(f)(2), Q&A-F5,
Proced. & Admin. Regs.; see Miller v. Commissioner, 115 T.C. 582,
589 n.2 (2000), affd. 21 Fed. Appx. 160 (4th Cir. 2001); see also
sec. 301.6330-1(f)(2), Q&A-F5, Proced. & Admin. Regs.; Magana v.
Commissioner, 118 T.C. 488, 493-494 (2002).
In her petition, petitioner failed to raise a spousal
defense, make a valid challenge to the appropriateness of
respondent’s intended collection action, or offer alternate means
of collection. A petition for review of a collection action must
clearly specify the errors alleged to have been committed in the
notice of determination. Rule 331(b)(4). Any issues not raised
in the assignments of error are deemed to be conceded by
petitioner. Id.; see Goza v. Commissioner, supra at 183; see
also Lunsford v. Commissioner, 117 T.C. 183, 185-186 (2001).
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