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participated meaningfully, as confirmed by our examination of the
transcript of the trial proceedings. This Court sustained the
deficiencies determined by respondent–-which exceeded the refunds
petitioner had claimed-–and entered decision for respondent.
Wooten v. Commissioner, T.C. Memo. 2000-54, appeal dismissed (5th
Cir. 2000). In so doing, this Court did not adjudicate
petitioner's complaints that she had never agreed to the transfer
of her refunds to the Department of Human Services and the
Department of Agriculture, nor did the Court adjudicate her
dispute over the existence and amounts of her obligations to
those agencies. This, the Court explained, was because it lacked
jurisdiction to restrain or review any credit or reduction by the
Commissioner under section 6402 (citing section 6512(b)(4) and
Savage v. Commissioner, 112 T.C. 46 (1999)).
On or about April 5, 2000, respondent assessed the
deficiencies and related interest against petitioner in the
following amounts:
Tax Year 1995 1996 1997 Totals
Deficiency $3,759.00 $4,208.00 $1,919.00 $9,886.00
Interest 1,471.77 1,555.67 317.44 3,344.88
Totals 5,230.77 5,763.67 2,236.44 13,230.88
On or about April 15, 2001, respondent applied a $3,478
refund claimed by petitioner on her taxable year 2000 tax return
to the balance then due on her 1995 tax year account.
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