Individual income taxation

Sixth Circuit affirms district court’s holding that the taxpayer’s refusal to cash a refund check did not keep the controversy alive in his case.

The court held that the notice was not sent
to the taxpayer’s last known address.

The IRS’s setoffs of tax prepayments were invalid, the appellate court holds, remanding the case to the Tax Court.

Sec. 7463(b) forecloses a review of the Tax Court’s dismissal, the appellate court holds.

Rejection of the taxpayer’s proposed collection alternatives was ‘hasty,’ the Tax Court finds.

A notice of deficiency’s petition filing deadline controls despite, in an ‘obvious mistake,’ being more than a year after the notice’s mailing date.

Although mailed after the 90- day deadline had expired, the petition was timely because it was filed within a 14-day extension provided under Sec. 7451(b)(1).

When a private delivery service is used, it must be one the IRS has specifically identified to satisfy Sec. 7502, the Tax Court holds.