James W. Davis and Teri A. Davis - Page 9

                                        - 8 -                                         
               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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