The newest courtroom stated that even when the 625,100000 was a deposit, it turned into an installment in the event the Internal revenue service used they to help you his a good taxation obligations. Becoming a deposit less than Sec. 6603, the newest remittance need to be created before the brand new Irs assesses the newest taxation. Ahmed argued the way it is wasn’t moot since the 625,000 try just in initial deposit rather than an installment of the income tax.

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The fresh Taxation Courtroom doesn’t have the newest jurisdiction to choose whether or not there’s a keen overpayment; as well, it can’t acquisition a reimbursement or credit away from fees in the a good continuing produced under Sec. 6330. Ahmed objected and you may asserted that the newest tax liability wasn’t paid back entirely while the 625,100 is actually simply a deposit, maybe not a cost. Within the December 2021, the fresh Taxation Court held you to definitely a great taxpayer’s remittance is actually a fees while the taxpayer labeled the newest remittance as the in initial deposit and you can said he had been distribution it pursuant in order to Rev. Proc.

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