-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.
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