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