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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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