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that year. Sec. 7442; Hesse v. Commissioner, T.C. Memo. 1997-
333, and cases cited therein at note 6.
We have considered petitioner's remaining arguments and find
them without merit.
Conclusion
We lack jurisdiction over the taxable year 1992.
Accordingly, petitioner's Motion for Leave to File Amended
Pleading will be denied.4
To give effect to the foregoing,
An order denying petitioner's
motion will be issued.
4 We note that although petitioner cannot pursue a case
in this Court as to the taxable year 1992, petitioner is not
without a judicial remedy. Thus, petitioner may pay the tax,
file a claim for refund with the Internal Revenue Service, and,
if the claim is denied, sue for a refund in the appropriate
Federal District Court or the United States Court of Federal
Claims. McCormick v. Commissioner, 55 T.C. 138, 142 (1970).
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