Donald R. Cooley and Cathy A. Cooley - Page 27

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              Petitioners additionally contend that the $2,564 refund                 
         claimed on their Form 1040 for their 2001 taxable year should be             
         applied against their liabilities in the instant case.                       
         Petitioners also contend that an alleged overpayment of $4,215.41            
         should be applied against their tax liabilities.  Petitioners                
         attached a document to their brief, purportedly from the Internal            
         Revenue Service, dated March 28, 2002, which indicated that an               
         overpayment of $4,215.41 was applied against the deficiencies in             
         their 1991, 1992, and 1993 taxable years.  The document does not             
         indicate the year to which the alleged overpayment relates.                  
              Petitioners’ 2001 Form 1040 and the March 28, 2002, letter              
         are not part of the record in this fully stipulated case.  See               
         Rule 91(e).  We shall not examine documents that are not part of             
         the record.  Accordingly, petitioners’ overpayment and refund                
         claims are unsubstantiated.                                                  
              We have considered all of the contentions and arguments of              
         the parties that are not discussed herein, and we find them to be            
         without merit, irrelevant, or moot.                                          
















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