- 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