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that in February 2007, respondent filed with the Campbell County
Clerk in Gillette, Wyoming, a Certificate of Release of Federal
Tax Lien reciting that petitioners had satisfied the taxes and
“all statutory additions” for 1995, 1998, 2002, and 2003.
Finally, we note that if petitioners think that they have
overpaid their liability for any of the years in issue, then
petitioners may have a judicial remedy in the form of a civil
action for refund in the appropriate U.S. District Court or the
U.S. Court of Federal Claims. See sec. 7422; see also 28 U.S.C.
secs. 1346(a)(1), 1402(a).5 Because such actions are governed by
strict procedural rules, petitioners may care to consult a
competent tax professional familiar with such matters.
5 Civil actions for refund under sec. 7422 are not
cognizable in the Tax Court. Indeed, our jurisdiction to even
determine overpayments is narrowly circumscribed. E.g., sec.
6512(b)(1).
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Last modified: November 10, 2007