- 6 - challenged those tax deficiencies in a prior Tax Court case, petitioner cannot now do so in this proceeding. See Sego v. Commissioner, 114 T.C. 604, 610 (2000). Because petitioner did not file her request for an Appeals Office hearing regarding respondent’s December 15, 2005, notice of tax lien filing until March 8, 2006, and because respondent properly conducted not a section 6330 collection hearing, but rather an equivalent hearing and issued to petitioner an adverse decision letter, no appeal to this Court lies with regard thereto. Rule 330; Kennedy v. Commissioner, 116 T.C. 255, 261-62 (2001); sec. 301.6320-1(i)(1), Q&A-I5, Proced. & Admin. Regs. Petitioner’s failure in her petition to raise specifically interest abatement and her failure to claim a credit against her Federal income taxes for payments made to respondent by petitioner’s former husband constitute petitioner’s abandonment or concession thereof. Rule 331(b)(4); Lunsford v. Commissioner, 117 T.C. 183, 185-86 (2001). Further, and alternatively, with regard to any claim for interest abatement, petitioner is silent as to what action of respondent would support interest abatement (i.e., petitioner has failed to allege any error or delay that occurred in this case asPage: Previous 1 2 3 4 5 6 7 NextLast modified: November 10, 2007