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DEAN v. COMMISSIONER

Dkt. No. 23403-05.

94 T.C.M. 391 (2007)

T.C. Memo. 2007-311

Gary Dean and Teri Colleen Madden v. Commissioner.

United States Tax Court.

October 15, 2007.

Attorney(s) appearing for the Case

Gary Dean and Teri Colleen Madden, pro sese.

Hans Famularo, for respondent.

MEMORANDUM OPINION

Marvel, Judge:

Respondent determined a deficiency in petitioners' Federal income tax of $1,779 for 2003. The issue for decision is whether we have jurisdiction to review the crediting by respondent, pursuant to his authority under section 6402(a),1 of an overpayment made by petitioners in 2003 towards petitioners' unpaid 1991 and 1992 tax liabilities.

Background

Petitioners resided...

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