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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 withheld
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Last modified: March 27, 2008