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COHEN, Chief Judge: This case was assigned to Special Trial
Judge Robert N. Armen, Jr., pursuant to the provisions of section
7443A(b)(3) of the Internal Revenue Code of 1986, as amended, and
Rules 180, 181, and 182.1 The Court agrees with and adopts the
Opinion of the Special Trial Judge, which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
ARMEN, Special Trial Judge: Respondent determined a
deficiency in petitioner's Federal income tax for the taxable
year 1993 in the amount of $5,926.
After concessions by petitioner, the only issue for decision
is whether this Court has jurisdiction to decide whether
respondent properly applied an overpayment of tax for 1993, the
taxable year in issue, to assessed liabilities for taxable years
not in issue in this case. We hold that this Court does not have
jurisdiction to decide this matter.
FINDINGS OF FACT
Some of the facts have been stipulated, and they are so
found. Petitioner resided in New York, New York, at the time
that his petition was filed with the Court.
Petitioner made three estimated tax payments for 1993, the
taxable year in issue, in the total amount of $31,000.
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the taxable year in
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
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