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joint and several liability encompasses a refund request). This
claim was filed more than 3 years after the filing of the 1995
return on April 15, 1996, and more than 2 years after respondent
credited the 1997 overpayment against a portion of petitioner’s
1995 tax liability on June 29, 1998. Secs. 6511(a) (providing
that to obtain a refund of the overpayment, a taxpayer must file
a refund claim within the later of 3 years from the date the
return was filed or 2 years from the date the tax was paid),
7422(d).
Thus, petitioner is not entitled, pursuant to section
6511(b)(1), to a refund of her overpayment relating to 1995.
Contentions we have not addressed are irrelevant, moot, or
meritless.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011