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the same amounts and characterizations of gross income determined
in the notices of deficiency sent to petitioners. In their
answer, petitioners claim that they do not have the necessary
records to verify the request for admissions and state that they
assume the requested admissions are accurate. We deem
petitioners’ response a concession as to the amounts and
characterizations of gross income determined in the notices of
deficiency for the years in issue. See Rule 90(c).
The remaining issue for purposes of respondent’s motion is
whether petitioners incurred a loss in 1987 which they may use to
offset their gross income for the years in issue. Petitioners
argue that they may offset their gross income with a carryforward
loss that they claim was caused by respondent’s illegal and
unconstitutional seizure activities against assets of IEEI, the
Alternative Energy entities, and Mr. Tonn in March of 1987.4
4Petitioners present lengthy arguments in support of their
contention that respondent’s agents engaged in illegal and
unconstitutional collection activities. We generally do not
address such arguments. See, e.g., Kerr v. Commissioner, 5
B.T.A. 1073, 1095 (1927). We note that petitioners have pursued
their claims that respondent’s agents engaged in illegal and
unconstitutional collection activities in District Court, but
those claims have been unsuccessful. See, e.g., Tonn v. United
States, 210 F.3d 379 (8th Cir. 2000); Tonn v. United States, 78
AFTR 2d 96-5631 (D. Minn. 1996), affd. without published opinion
108 F.3d 1382 (8th Cir. 1997); Tonn v. United States, 847 F.
Supp. 711 (D. Minn. 1993), affd. sub nom. Tonn v. Forsberg, 27
F.3d 1356 (8th Cir. 1994). Petitioners also contend that they
did not receive notice of the alleged seizure in March of 1987,
and, thus, the property seized must be returned. This argument
does not bear on the issue of whether petitioners are entitled to
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