Article: SUSAN BOCOCK AND JACK CARL RYALS, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

Docket No. 11161-05. Filed October 30, 2006.

Ps made certain payments before filing their 2002 tax return and intended that the payments be applied to their 2002 taxable year. R first credited the payments to Ps' 2002 taxable year but later credited the payments to P husband's outstanding tax liability from 1978 after Ps filed their 2002 tax return on which they claimed an overpayment. R subsequently determined a deficiency in income tax and an accuracy-related penalty pursuant to sec. 6662(a), I.R.C., for Ps' 2002 taxable year and sent Ps a notice of deficiency. Ps timely petitioned this Court for a redetermination of the deficiency and contended that the Court has deficiency jurisdiction ...

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