Ragnhild Anne Westby - Page 6

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          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 as           

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