-8- and that petitioners’ unsupported allegations create no triable issue of fact regarding the “punitive conduct” by the IRS personnel. Regarding petitioners’ request to refer this case to a different forum, we observe that this Court has jurisdiction over the appeal of the administrative determinations where the underlying tax liability concerns unpaid income taxes, as opposed to the other taxes. See, e.g., Goza v. Commissioner, supra; Danner v. United States, 208 F. Supp. 2d 1166 (E.D. Wash. 2002); Gillett v. United States, 233 F. Supp. 2d 874 (W.D. Mich. 2002). Therefore, we decline to grant petitioners’ request. We have considered all arguments raised by the parties and have found those arguments not discussed herein to be irrelevant and/or without merit. Accordingly, An appropriate order and decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7 8
Last modified: May 25, 2011