Crevenne C. and Barbara A. Carrillo - Page 8

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          and demand for payment, any “valid notice of deficiency”,                   
          authorization under section 7401 from the Secretary for the                 
          instant collection actions, and verification from the Secretary             
          that all applicable requirements were met).  Petitioners pray               
          that this Court declare invalid and “Nullify completely” the                
          January 21, 2004, determination, and “not remand” the case to the           
          IRS for a new hearing; order the Government to cease enforcement            
          activity and release the filed notice of lien; and order the                
          Government to reimburse petitioners for all costs incurred in               
          submitting the instant petition.5                                           
               After the pleadings were closed in this case, petitioners              
          reiterated their request that this Court declare invalid the                
          determination at issue by means of a document and multiple                  
          attachments filed on April 5, 2004, as a motion to dismiss for              
          lack of jurisdiction.  Petitioners supplemented this motion with            
          additional materials on April 19, 2004, and respondent filed a              
          notice of objection on April 29, 2004.  The Court denied                    
          petitioners’ motion on May 13, 2004.                                        
               Petitioners thereafter served a request for admissions on              
          respondent and filed a copy with the Court on June 1, 2004.  The            
          30 paragraphs generally asked respondent to admit to a broad                


               5 The Court notes that to the extent that the petition seeks           
          reasonable administrative and/or litigation costs pursuant to               
          sec. 7430, any such claim is premature and will not be further              
          addressed.  See Rule 231.                                                   





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