Sandoval Lua v. United States

Tax ease; effectiveness of taxpayers’ consent to assessment of taxes without notice of' deficiency; assessment within statutory limitations period; payment of tax rather than deposit of funds.

OPINION AND ORDER

LETTOW, Judge.

Plaintiffs Armando Sandoval Lua and Ya-dira Sandoval (“taxpayers”) seek a refund of income taxes paid in 2008 after an audit by the Internal Revenue Service (“IRS”) of their 2003 and 2004 tax returns. Pending before the court are the parties’ cross-motions for summary judgment. Def.’s Mot. for Summary Judgment, ECF No. 56-1 (“Def.’s Mot.”); Pis.’ Cross-Mot. for Summary…