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(an offset under section 6402 does not constitute a levy action).
If petitioner thinks that he has overpaid his liabilities, as he
has alleged in the petition, then it is possible that he may be
able to file a claim for refund with the Internal Revenue Service
and, if the claim is denied, sue for a refund in the Federal
District Court or the Court of Federal Claims. See McCormick v.
Commissioner, 55 T.C. 138, 142 (1970).
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
An order of dismissal for
for lack of jurisdiction will
be entered.
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Last modified: May 25, 2011