Carl and Lisa Neugebauer - Page 8

                                         -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