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reflects that this assessment of additional tax and interest was
“abated” on November 8, 2004.
On October 27, 2004, petitioners filed a refund suit in U.S.
District Court for the District of Oregon, at docket No. CV-04-
01563-KI. By opinion and order dated March 16, 2005, the
District Court dismissed petitioners’ suit for lack of subject
matter jurisdiction. On May 22, 2006, the Court of Appeals for
the Ninth Circuit affirmed the District Court’s dismissal for
lack of subject matter jurisdiction. Bhattacharyya v.
Commissioner, 180 Fed. Appx. 763 (9th Cir. 2006).
E. Petitioners’ 2000 Federal Income Tax Return
Petitioners filed a joint Federal income tax return for 2000
on May 19, 2003. Petitioners reported wages, salaries, tips,
etc., of $746,191, the amount reported by Intel on the Form W-2.
On an attached “Exhibit II”, petitioners summarized their IRA and
retirement plan distributions and rollovers as follows:
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