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.
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