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attributable to her deceased husband’s interest in Robotics for
1983 and 1984, and that she is entitled to relief from joint
liability for tax under section 6015(f). The relief that
petitioner requests is a refund of $23,157.79 for 1983 and
$5,513.20 for 1984.
An informal refund claim must have a written component that
gives the Commissioner sufficient notice of the fact that the
taxpayer believes he or she has been erroneously subjected to tax
and that a refund is sought for a certain year or years. Angelus
Milling Co. v. United States, 325 U.S. 293, 297-298 (1945);
United States v. Kales, 314 U.S. 186, 193-194, 196 (1941);
Disabled Am. Veterans v. United States, 227 Ct. Cl. 474, 650 F.2d
1178, 1180 (1981); Missouri Pac. R.R. Co. v. United States, 214
Ct. Cl. 623, 558 F.2d 596, 598 (1977); Barenfeld v. United
States, 194 Ct. Cl. 903, 442 F.2d 371, 374-375 (1971); Am.
Radiator & Standard Sanitary Corp. v. United States, 162 Ct. Cl.
106, 318 F.2d 915, 920 (1963); New England Elec. Sys. v. United
States, 32 Fed. Cl. 636, 641 (1995).
B. Whether Letters Petitioner and Kohl Sent to Respondent
Before September 5, 1997, Constitute a Claim for Refund of
Taxes Petitioner Paid Relating to Robotics
Petitioner contends that various letters she and Kohl sent
to respondent before September 5, 1997, made clear that Robotics
was her husband’s investment, that she did not know anything
about Robotics, that she was requesting a refund of tax paid for
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