Ja Refunds 5. Sanjay negligently failed to mail his Year 1 return until May 10, Year 4. When filed, the return reflected a tax liability of $3,000 for Year 1, and wage withholding credits of $2,500 (consistent with the Form W-2 included with the return). Accordingly, he mailed a $500 payment in with the return, which the IRS received with the return on May 13, Year 4. On April 1, Year 7, the IRS mailed Sanjay a notice of deficiency in the amount of $1,000 based on income Sanjay allegedly received but did not report. A. Assume that Sanjay failed to respond in any way to the notice of deficiency, and the IRS assesses the $1,000 deficiency on July 15, Year 7. Is the assessment timely? B. Alternatively, assume instead that Sanjay responded to the notice by filing a petition in the United States Tax Court on April 30, Year 7. He alleges never having received the income referenced in the notice of deficiency. In addition, he alleges that he is entitled to additional deductions entitling him to a refund of $700, Assuming that the Tax Court agrees with Sanjay on the merits, does the Tax Court have jurisdiction to order the IRS to award Sanjay a $700 refund? C. Do both the statute of limitations on assessment of a $1,000 deficiency for Sanjay's Year 1 tax year and the statute of limitations for Sanjay to claim a refund of $700 with respect to his Year 1 tax year expire on the same day? Is your answer affected by whether or not Sanjay petitions the Tax Court?