- 3 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011