Question
Adrian has received a notice of deficiency from the IRS in the amount of $5000 with respect to his Year 1 tax year. After receiving
Adrian has received a notice of deficiency from the IRS in the amount of $5000 with respect to his Year 1 tax year. After receiving the notice, and within the 45 days of the date on the notice, Adrian mailed the IRS a $5000 check with only the notion Year 1 Taxes on the memo line of the check. A.) Is Adrian still entitled to petition the Tax Court in response to the notice of deficiency? B.) How would it affect Adrians rights if instead he had printed deposit Year 1 taxes on the memo line of his check? C.) Would your answer to Part A differ if Adrian had mailed in $5000 after receiving a 30-day letter but before receiving the notice of deficiency? D.) Assume that Adrian does not petition the Tax Court. If the statute of limitations on assessment expires after Adrians remittance of the $5000 without an assessment by the IRS, is the IRS obligated to refund the $5000 to Adrian?
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