- 14 - erred by determining that the Federal tax lien should not be withdrawn. At trial, petitioner testified that the Federal tax lien was affecting his business and petitioners would be able to pay their taxes if the lien was removed. On brief, petitioners requested that the Court find as a fact that “The Petitioner believes that if the Federal Tax Lien was taken off, he would be able to earn money to pay his 1999 tax liability.” However, petitioners did not argue on brief that respondent abused his discretion by determining that the Federal tax lien should not be withdrawn. Rule 331(b)(4) provides that, in a lien or levy action, the petition must include “Clear and concise assignments of each and every error which the petitioner alleges to have been committed in the notice of determination. Any issue not raised in the assignments of error shall be deemed to be conceded.” Because petitioners did not allege in their petition that respondent abused his discretion by determining that the Federal tax lien should not be withdrawn and because petitioners did not address it on brief, we find that petitioners have conceded the issue. Therefore, we hold that respondent did not abuse his discretion by determining that a Federal tax lien was appropriately filed and would remain in effect until petitioners’ tax liability was satisfied.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007