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contend that they did not receive refunds to which they were
entitled for 1984, 1987, and 1995 and that the amounts not
refunded should be applied to their outstanding liabilities.
Unless otherwise indicated, all section references are to the
Internal Revenue Code in effect for the years in issue.
Background
Some of the facts have been stipulated, and the stipulated
facts are incorporated in our findings by this reference.
Petitioners resided in Marlton, New Jersey, at the time that they
filed their petition.
On March 22, 2001, the Internal Revenue Service sent to
petitioners a notice of filing of a notice of tax lien with
respect to income tax owing for 1990, 1991, 1992, and 1996. The
total taxes that were the subject of the lien approximated
$17,115. Petitioners requested a hearing under section 6330. At
the hearing, petitioners contended that they had not received
refunds totaling approximately $14,000 for 1984, 1987, and 1995.
At the hearing, petitioners were presented with transcripts of
their accounts for 1984, 1987, 1990, 1991, 1992, 1995, and 1996.
Subsequent to the hearing, canceled checks that were
endorsed by petitioners were located. The checks reflected
refunds of $7,611.83 for 1984 and $1,003.38 for 1995. Although
the transcript of petitioners’ account for 1987 reflected a
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