Ella Louise Wooten - Page 4

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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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