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of petitioners’ arguments.2 See Wooten v. Commissioner, T.C.
Memo. 2003-113.
Reviewed and adopted as the report of the Small Tax Case
Division.
An appropriate order and
decision will be entered.
2In Thomas v. Bennett, 856 F.2d 1165 (8th Cir. 1988), the
court held that the purpose of the jurisdictional limitation is
to relieve the Secretary of the Treasury from the burden of
handling challenges to the substantive merits of debts underlying
requested refund setoffs, and that Congress determined that the
appropriate place for litigation of such claims is with the
agency to which the obligation is owed, recognizing that the IRS
does not have the information and resources needed to adjudicate
the validity of the underlying obligation.
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