Samuel and Bernice Boone Trust - Page 8




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            also Estate of Meyer v. Commissioner, 84 T.C. 560, 562 (1985);                             
            Adams v. Commissioner, 72 T.C. 81, 84 (1979), affd. without                                
            published opinion 688 F.2d 815 (2d Cir. 1982).  With exceptions                            
            not germane here, this Court’s jurisdiction is generally limited                           
            to redetermining deficiencies in income taxes, estate and gift                             
            taxes, and certain specified excise taxes that are subject to the                          
            deficiency procedures outlined above.  See secs. 6214, 7442; see                           
            also Estate of Meyer v. Commissioner, supra at 562; Judd v.                                
            Commissioner, 74 T.C. 651, 653 (1980).                                                     
                  In this case, respondent is attempting to collect an alleged                         
            erroneous refund resulting from petitioner’s alleged                                       
            overstatement of income taxes withheld.  The assessments at issue                          
            were not subject to the deficiency procedures but instead were                             
            subject to the summary assessment procedures of section                                    
            6201(a)(3).  Under those procedures, overstatements of withheld                            
            income taxes are generally treated in the same manner as                                   
            mathematical or clerical errors appearing on the return, except                            
            that in the case of an assessment of an overstated credit for                              
            withholding, the taxpayer has no right to request an abatement.                            
            See secs. 6201(a)(3), 6213(b)(1) and (2).  Therefore, summary                              
            assessments with respect to overstatements of withheld taxes                               











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