Martin A. Glowinski v. Commissioner of Internal Revenue

This is a petition for review of a decision of the Tax Court of the United States. The Commissioner of Internal Revenue sent Mr. Glowinski a notice of deficiency for the years 1951, 1952 and 1953. Penalties for failure to file returns were added to the proposed tax. Mr. Glowinski insisted that he had erroneously paid taxes for the years 1948, 1949 and 1950, and he urged that the Tax Court determine his correct taxes for those years and offset them against the claimed taxes for the later years. The Tax Court correctly decided that it had no jurisdiction to consider the prior years.…