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The newest judge stated that even when the 625,000 was a deposit, it turned a cost in the event the Internal revenue service applied they to his an excellent tax liabilities. Getting a deposit below Sec. 6603, the new remittance have to be made before the brand new Internal revenue service analyzes the brand new taxation. Ahmed debated the situation was not moot because the 625,one hundred thousand are just in initial deposit rather than a payment of your own tax.
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The newest Taxation Judge doesn’t have the fresh jurisdiction to determine if or not there is a keen overpayment; simultaneously, it cannot buy a refund otherwise borrowing of taxes in the a great continuing delivered below Sec. 6330. Ahmed objected and you may said that the fresh tax responsibility was not paid off entirely as the 625,100000 is actually merely in initial deposit, perhaps not an installment. Inside December 2021, the brand new Income tax Judge stored you to definitely an excellent taxpayer’s remittance is actually an installment whilst taxpayer branded the fresh remittance since the in initial deposit and you may mentioned he was distribution they pursuant in order to Rev. Proc.
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