Stebco Inc. v. United States

ORDER

Taxpayers Rafael Carrillo-Barron and Norma Fregoso Carrillo (“the Carrillos”) bring this motion to dismiss the government’s appeal from the district court’s order, 733 F.Supp. 1387, denying the government’s motion to dismiss for lack of venue. Taxpayers also request sanctions. The motion to dismiss is granted, and the request for sanctions is denied.

This case arises out of jeopardy assessments made against the Carrillos by the *557IRS pursuant to 26 U.S.C. § 6861,1 which permits the IRS to assess and collect a tax deficiency immediately if the IRS believes delay will jeopardize the desired…