- 4 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011