Case: Time Barred Overpayment Claims to Credit Tax Liability Not Allowed (T.C. Summ.) (IRC §6511)

Where a taxpayer’s overpayment claim is time barred under tax code Section 6511, any offset claim for credit from another tax year would also be time barred, the U.S. Tax Court held in a nonprecedential summary opinion. IRS issued Taxpayer a notice of deficiency and he did not file a petition disputing that notice of deficiency. During the Collection Due Process hearing, Taxpayer asserted that he had not received full refunds for multiple tax years. The IRS explained that Taxpayer had been issued a refund after filing his original tax return and that the additional tax for that year was ...