McNaughton v. United States

Pro Se; refund claim untimely under 26 U.S.C. § 6511(a); lack of jurisdiction to hear partner-level refund suits under 26 U.S.C. § 7422

OPINION AND ORDER

FIRESTONE, Judge.

In this tax refund suit, pro se plaintiffs Christopher J. McNaughton and Judith I. MeNaughton, husband and wife (collectively, “the plaintiffs” or “the McNaughtons”), seek $154,900 plus interest and unspecified penalties stemming from their 2005 and 2007 tax years. Their three-count complaint seeks tax refunds related to accumulated passive losses from several federally registered Publicly Traded Partnerships (“PTPs”).…