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jurisdiction to decide the issue. Petitioner agreed to settle
his case. On April 14, 1993, he signed a decision document
agreeing to deficiencies of $6,330 for 1980 and $5,717 for 1983,
and to certain concessions as to additions to tax and an
additional amount under section 6621(c). The decision document
also states, consistent with the settlement computation of June
27, 1989, that petitioner has net tax payments of $5,717 for
1983.
On July 26, 1993, petitioner sent a check for $1,567.51 to
the IRS for his 1980 tax liability. In response to a letter from
petitioner dated February 16, 1994, the Court wrote to him
explaining that jurisdiction did not currently exist to recompute
the statutory interest to be assessed on his 1980 tax deficiency.
Petitioner alleged in his letter to the Court that the amount he
was now disputing was "the RE-PAYMENT of money the IRS sent me in
error, plus nine (9) years of compounded interest."
In response to petitioner's correspondence to Commissioner
Michael P. Dolan, dated November 13, 1997, the Acting District
Taxpayer Advocate sent petitioner a letter dated January 7, 1998,
attempting to explain petitioner's transcripts of account for
1980 and 1983.
On April 27, 1999, respondent received a Form 843, Claim for
Refund and Request for Abatement, filed by petitioner. In an
attachment to the form, petitioner states that "The two sources
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