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Tsutomu Tedokon, pro se.
Sylvia L. Shaughnessy, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
NIMS, Judge: This case arises from a petition for judicial
review filed in response to a “NOTICE OF DETERMINATION CONCERNING
COLLECTION ACTION(S) UNDER SECTION 6320 and/or 6330” (Notice).
Unless otherwise indicated, all section references are to the
Internal Revenue Code in effect for the years in issue, and all
Rule references are to the Tax Court Rules of Practice and
Procedure. Respondent does not challenge the Court’s
jurisdiction over this case, and petitioner does not assert that
respondent’s Appeals Officer did not take into consideration all
of the matters required by section 6330(c)(3). Consequently, the
only issue for decision is the substantive question of whether
section 6511 precludes the allowance of any portion of
petitioner’s 1991 overpayment of tax as a credit against his
liabilities for 1993, 1994, 1995, and 1997.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulations of the parties, with accompanying exhibits, are
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