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Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect our disposition of the disputed issue,
Decision will be entered
for respondent.
4(...continued)
case does not show any overpayment of tax for 2001; therefore,
the Court’s ancillary jurisdiction under sec. 6512 is not
implicated in this deficiency proceeding. See sec. 6213; cf.
secs. 6320, 6330 involving lien and levy actions (collection
actions).
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Last modified: May 25, 2011