Except Sometimes

Summer H. El Deeb, T. C. Memo. 2026-101, filed 9/29/26, claimed in her petition that she is “entitled to a $3,000 credit for an estimated tax payment for taxable year 2021 or an amount applied from taxable year 2020.” T. C. Memo. 2026-101, at p. 1.

Before my ultrasophisticated readers cry out with one voice “So what? Sections 6211(b)(1), 6402(b), and 6513(d),” that’s what Judge Courtney D. (“CD”) Jones says.”Furthermore, even if we had jurisdiction to consider this issue, Ms. El Deeb has conceded that she is not entitled to the $3,000 claimed credit for either an estimated tax payment or an amount carried over from a prior-year return.” T. C. Memo. 2026-101, at p. 7.