- 3 - On October 29, 2002, because of the reversal of the conversion of his IRA account back into a traditional IRA and because petitioner no longer had an obligation to report in his 2001 income the earnings from his IRA, petitioners filed with respondent an amended 2001 joint Federal income tax return reflecting gross income less the $55,065 in 2001 IRA earnings. This reduction in income created a $13,769 tax overpayment that petitioners claimed as a refund (refund claim). On July 24, 2003, in response to questions about petitioners’ refund claim, petitioner met with respondent’s Compliance Division officer and her supervisor. Both of respondent’s employees erroneously informed petitioner that petitioner’s reversal of his IRA account back into a traditional IRA was untimely and therefore that petitioners’ refund claim would be disallowed. Also on July 24, 2003, respondent’s Compliance Division mailed to petitioners a claim disallowance letter disallowing petitioners’ refund claim and stating that petitioners could appeal the disallowance to respondent’s Appeals Office. On September 4, 2003, petitioners’ accountant requested from respondent’s National Office of Chief Counsel a determination as to whether petitioners, on their amended 2001 tax return, timely 2(...continued) due date (including extensions) for the year in which the conversion took place.Page: Previous 1 2 3 4 5 6 7 8 9 10 NextLast modified: November 10, 2007