I’ve headlined two distinct blogposts as “Money-Back Guarantee”, 5/17/13 and 6/24/13. Each of those did provide for money back, but today’s blogpost, a designated hitter from STJ Daniel A. (“Yuda”) Guy, is anything but a guarantee that you’ll get your money back in Tax Court.

Tax Court’s labyrinthine jurisdiction, supposed to provide quick-and-cheap dispute resolution, instead provides quick-and-cheap dismissals. Here’s Reaz Ahmed & Ayesha Khatun, Docket No. 7292-13S, filed 3/7/14, getting the boot.

Reaz and Ayesha never got a SNOD or a NOD, so IRS moves for summary judgment, and wins, of course.

“The notice of deficiency has been described as ‘the taxpayer’s ticket to the Tax Court’ because without it there can be no prepayment judicial review by this Court of the deficiency determined by the Commissioner.

“The record reflects that (1) respondent did not issue a notice of deficiency or other notice of determination to petitioners for the taxable year …, and (2) petitioners are in fact attempting to prosecute a refund action. It is well settled that a letter disallowing a claim for a credit or refund does not constitute a notice of deficiency under I.R.C. section 6212. It follows that we lack jurisdiction in this case.” Order, at pp. 1-2. (Citations omitted).

Maybe the Tax Court website needs to explain this to taxpayers.