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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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