T.C. Memo. 2000-349 UNITED STATES TAX COURT STEPHEN C. LOADHOLT TRUST, DEBRA M. LANCE TRUSTEE, ET AL.,1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 18158-99L, 18159-99L, Filed November 13, 2000. 18521-99L. On their 1997 income tax returns, Ps reported zero tax liability and claimed refunds resulting from claimed income tax withholding credits. R paid Ps the claimed refunds but later determined that the payments of refunds were in error, as Ps had made no income tax payments for which the withholding credits were claimed. After R made summary assessments of the erroneous refunds, Ps requested due process hearings. After R issued negative determination letters, Ps filed petitions for judicial review of R’s administrative determinations. R filed motions to dismiss for lack of jurisdiction. Held, because the Court lacks jurisdiction over the underlying tax liabilities that R is attempting to collect, the Court lacks jurisdiction to review the administrative determinations in dispute. 1 The following cases are consolidated herewith: Samuel Lance, Jr. Trust, docket No. 18159-99L; and Debra M. Lance Trust, docket No. 18521-99L.Page: 1 2 3 4 5 6 7 8 9 10 Next
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