Crevenne C. and Barbara A. Carrillo - Page 3

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               Petitioners thereafter filed a series of refund claims                 
          and/or amended returns with respect to their 1997 and 1998                  
          returns.  In these documents petitioners attempted to change                
          their reporting position to reflect zero for all pertinent items            
          of income and deduction and to request refunds for the balance of           
          tax withheld and not previously refunded.  The IRS issued denials           
          of these claims and advised petitioners therein of their right to           
          contest disallowance by an administrative appeal or by                      
          instituting suit in the U.S. District Court or U.S. Court of                
          Federal Claims within 2 years.                                              
               Respondent assessed additional tax and interest with respect           
          to 1997 and 1998 on August 14 and December 11, 2000,                        
          respectively.2  Notices of balance due for 1997 were issued on              
          August 14, 2000, September 18, 2000, December 4, 2000, January 8,           
          2001, and May 27, 2002.  Notices of balance due for 1998 were               
          issued on December 11, 2000, January 15, 2001, and May 27, 2002.            
               On their returns for 1999 and 2000, petitioners reported               
          zero for all items of income and deduction and requested refunds            
          for the full amount claimed thereon as Federal income tax                   
          withheld.  They attached to each of these returns written                   
          statements espousing their assertions that no law required them             


               2 The record contains little information as to the                     
          circumstances surrounding these assessments.  Petitioners,                  
          however, have not separately challenged them apart from their               
          generalized objections to liability for any income taxes.                   





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