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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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