- 8 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011