Opinion
1732-21
02-27-2024
Barrie Blueian Sr. a.k.a Barrie J. Blueian & Brenda Yadira Blueian, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
MARK V. HOLMES JUDGE.
This case is on the March 7, 2024 Reno, Nevada trial calendar. On January 5, 2024 petitioners moved for summary judgment. They state four grounds:
• The IRS sent them a letter in March 2022 stating that they owed nothing;
• the IRS seized "monies absent judicial order while pending case before the court and without petitioners' consent;"
• the IRS "engaged in bad behaviors concerning this matter" by continuing to send information about their case to their former lawyer after receiving a revocation of his power of attorney; and
• the IRS refused to settle their case. None of these arguments show that the Blueians are entitled to judgment as a matter of law.
This case is their challenge to a notice of deficiency for their 2017 and 2018 tax years. It is all about how much tax, if anything, they owe the IRS on their income for those years. The March 2022 letter and seizure of their 2019 refund both relate to their 2016 tax year and are irrelevant to their 2017 and 2018 tax years. Whether or not the IRS sent information to their lawyer, or refused to settle this case, has nothing to do with the question of how much they owe for any year.
It is therefore
ORDERED that petitioners' January 5, 2024 summary-judgment motion is denied.