Jarvis

These two tax cases come before the court on defendant’s motions to dismiss. In their original petitions, plaintiffs (joint taxpayers appearing pro se) asked that we "disallow” two notices of deficiency issued by the Internal Revenue *728Service, pertaining to plaintiffs’ tax obligations for 1972, 1973, and 1974. Defendant moved to dismiss the petitions on the grounds that plaintiffs had not alleged they had paid the taxes demanded by the IRS and made timely claims for refund, as required by 26 U.S.C. § 7422(a). Moreover, defendant pointed out, plaintiffs state that they have brought the dispute…