Ella Louise Wooten - Page 8

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                                     Discussion                                       
               In her petition and amended petition in this case and in her           
          objections to respondent's motion, petitioner attempts to                   
          challenge the existence or amounts of her underlying tax                    
          liabilities for the years in issue by bringing up again and                 
          elaborating on allegations and arguments she made in the prior              
          case in this Court that upheld the deficiencies determined by               
          respondent.  Wooten v. Commissioner, T.C. Memo. 2000-54, appeal             
          dismissed (5th Cir. 2000).                                                  
               In an effort to give this pro se petitioner the benefit of             
          the doubt, we broadly interpret petitioner's Form 12153 request             
          for a hearing, her petition to this Court, and her objections to            
          respondent's motion as embodying both (1) an effort to dispute              
          the deficiencies determined by respondent and upheld by this                
          Court in Wooten v. Commissioner, supra, and (2) objections to               
          respondent's actions pursuant to section 6402 in paying the                 
          refunds claimed on her returns to the Mississippi Department of             
          Human Services and the U.S. Department of Agriculture.                      
          Issue 1:  Petitioner's Tax Liabilities                                      
               Petitioner's tax liabilities cannot be put in issue in this            
          case because they were decided in the prior case in this Court              
          that redetermined petitioner's tax liabilities for the years in             
          issue.  Section 6330(c)(4) provides in relevant part:                       








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