Case: Tax Court Jurisdiction for Refund Requires Notice of Deficiency (6th Cir.) (IRC §6213)

Petition for refund filed in Tax Court was properly dismissed for a lack of jurisdiction where the taxpayer never received a notice of deficiency, the Sixth Circuit Court of Appeals held. The court held that without a notice of deficiency, jurisdiction isn’t conferred upon the court. The taxpayer was seeking tax refunds for 17 years while he was wrongfully incarcerated. [Bass v. Commissioner, No. 18-1574 (6th Cir. Jan. 7, 2019) (unpub. op.)]

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