- 12 - Petitioner does not articulate any physical or mental impairment from which he suffered during any period at issue here. Instead, petitioner contends that his care-giving responsibilities provided to another while simultaneously earning a living somehow afford him the extraordinary benefits of section 6511(h). We disagree. While we sympathize with petitioner regarding his mother’s condition and the demands of his employment, those are the types of problems confronted by many taxpayers and are not the conditions contemplated in section 6511(h). Viewing the record in the light most favorable to petitioner, he cannot sustain his claim to the benefits articulated in section 6511(h). As the period of limitations articulated in section 6511 is not suspended by virtue of section 6511(h), we therefore lack jurisdiction to award petitioner a refund or credit. See secs. 6511 and 6512; Commissioner v. Lundy, 512 U.S. at 252; United States v. Brockamp, 519 U.S. 347 (1997). Accordingly, we grant respondent’s motion for summary judgment. An appropriate order and decision will be entered.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12
Last modified: May 25, 2011