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