Dudley Joseph Callahan and Myrna Dupuy Callahan v. Commissioner

130 T.C. No. 3

UNITED STATES TAX COURT DUDLEY JOSEPH CALLAHAN AND MYRNA DUPUY CALLAHAN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 5701-07L. Filed February 5, 2008. For 2003, Ps submitted Form 1040, U.S. Individual Income Tax Return, and Form 843, Claim for Refund and Request for Abatement, to R. R assessed a frivolous return penalty under sec. 6702, I.R.C., on account of both Ps’ 2003 Form 1040 and their 2003 Form 843. After receiving a final notice of intent to levy, Ps requested a hearing under sec. 6330, I.R.C. During their hearing Ps challenged the assessment…