- 5 - the period of limitations governing collection remained open with regard to assessments for the taxable years 1982 and 1985 that were recorded in 1986. The record does not reflect whether petitioner filed a refund suit in Federal District Court or the Court of Federal Claims with regard to her refund claims for the taxable years 1982 and 1985. See sec. 6532(a) (a taxpayer may file a refund suit under section 7422 after 6 months from the date of filing a claim for refund and within 2 years from the date of mailing of a notice of disallowance). Petitioner’s Tax Liability for 1998 Petitioner failed to file a tax return for 1998. On February 5, 2001, respondent filed a substitute for return for the taxable year 1998 on petitioner’s behalf. On April 30, 2001, respondent mailed to petitioner a notice of deficiency for 1998. Petitioner filed a petition for redetermination with the Court (assigned docket No. 9419-01) challenging the notice of deficiency. The deficiency respondent determined for petitioner’s 1998 taxable year was $87,811. The notice of deficiency included as an attachment a tax calculation summary in which respondent acknowledged that petitioner was entitled to a credit of $24,844 for tax withholding during 1998. The $24,844 amount comprised $13,665 withheld from petitioner’s wages and $11,179 withheldPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 NextLast modified: March 27, 2008