In Uncategorized on 02/12/2018 at 13:44

No, I didn’t misspell the international radiotelephone declaration of a non-life-threatening emergency. But it is a declaration that will have consequences for Panagiota Pam Sotiropoulos, Docket No. 19884-12, filed 2/12/18.

Judge Lauber finally gets around to tossing Pam’s petition for want of jurisdiction, because Section 905(c) backs up IRS’ contention that they “don’t need no stinkin’ SNOD” to hit Pam for the tax refund she got from HMRC (that’s Queen Elizabeth II’s revenooers), even if it later turns out Pam was not entitled to same and she paid the UK income tax for which she took credit long ago.

See my blogpost “Give It Back, Take It Back,” 5/1/17, and my blogpost therein cited, for Pam’s joust with UK and US.

So Pam’s petition is dismissed for want of jurisdiction.

But I’ll repeat my comment from last May: did she have a chance to contest? All Tax Court decided was (a) they could see if they had jurisdiction, and (b) they didn’t. Maybe I’ll get a blogpost out of a CDP, if Pam seeks one.


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