T.C. Memo. 2000-350
UNITED STATES TAX COURT
SAMUEL AND BERNICE BOONE TRUST, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 16141-99L. Filed November 13, 2000.
On its 1997 income tax return, P reported zero tax
liability and claimed a refund resulting from claimed
income tax withholding credits. R paid P the claimed
refund but later determined that the payment of the
refund was in error, as P had made no income tax
payments for which the withholding credits were
claimed. After R made summary assessment of the
erroneous refund, P requested a due process hearing.
After R issued a negative determination letter, P filed
a petition for judicial review of R’s administrative
determination. R filed a motion to dismiss for lack of
jurisdiction. Held, because the Court lacks
jurisdiction over the underlying tax liability that R
is attempting to collect, the Court lacks jurisdiction
to review the administrative determination in dispute.
Page: 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011