Michael E. Bowles Lynn G. Bowles v. United States

SPROUSE, Circuit Judge:

Michael E. Bowles and Lynn G. Bowles, his wife, appeal from the district court’s dismissal of their tax refund suit. The Bowles had attempted to assert claims for business-expense deductions incurred while away from their tax home claimed to be in Charlottesville, Virginia. The district court ruled that it lacked jurisdiction to hear these claims because the Bowles failed to assert in their administrative refund claim that Charlottesville was their tax home. We agree that the Bowles failed to assert this basis for recovery at the administrative level. We reverse,…