No, I’m not going to insult my ultrasophisticated readers by telling them about IRS’ Refund Tracker. No one who reads this my blog needs such babyfood. Rather, this is the story of Renee Elaine White, Docket No. 878-26S, filed 4/21/26, who wants Tax Court to give her “reimbursement for payments made with respect to the 2014, 2015, 2016, and 2017 tax years, for which petitioner was granted innocent spouse relief pursuant to Internal Revenue Code (I.R.C.) section 6015(c).” Order, at p. 1.

Renee stiped out her innocent spousery last October, no runs, no hits, no errors (no tax due, no refund due, no penalties due). But Renee claims runners left on base for the said four (count ’em, four) years of spouse’s tax obligations. IRS ripostes with “no SND, no NOD, no jurisdiction.”

Ch J Patrick J. (“Scholar Pat”) Urda calls Renee out at Tax Court.

“…the relief requested by petitioner—refunds for various tax years —is not within the Court’s authority to grant in this case. In a case based on a notice of deficiency, in which the Court must determine the correct amount of tax, this Court may make a determination concerning whether there has been an overpayment of tax. See I.R.C. § 6512(b). Otherwise, this Court does not have jurisdiction to make determinations concerning overpayments or refunds. Taxpayers generally have two years to file a lawsuit following the disallowance of a claim for refund. See I.R.C. §6532(a)(1). The Tax Court, however, is not the proper court in which to file such an action. A taxpayer may seek a judicial remedy for wrongful denial of refund claims—i.e., a refund suit in compliance with I.R.C. sections 6532(a)(1) and 7422(a)—either in the United States Court of Federal Claims, pursuant to 28 U.S.C. section 1491(a)(1), or in Federal district court pursuant to 28 U.S.C. section 1346(a)(1). Those statutes do not confer refund jurisdiction on the Tax Court. Accordingly, this Court cannot and does not decide whether petitioner is entitled to recover a refund….” Order, at p.2.

Edited to add, 4/21/26: Even if Tax Court had jurisdiction, see Order at p. 2. Renee submitted Form 843 refund claim two (count ’em two) months ago. Section 6532(a)(1) imposes a six-month cooling off period before a refund suit can be commenced, unless IRS sooner denies (which Renee doesn’t allege).