Panagiota Pam Sotiropoulos v. Commissioner

142 T.C. No. 15

UNITED STATES TAX COURT PANAGIOTA PAM SOTIROPOULOS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 19884-12. Filed May 5, 2014. I.R.C. sec. 901(a) permits a U.S. citizen or resident to claim a credit against her Federal income tax liability for income taxes paid to a foreign country. If such taxes are “refunded in whole or in part,” the taxpayer is required to notify the Secretary, who is authorized to redetermine the U.S. tax. I.R.C. sec. 905(c)(1). Any tax due as a result of the Secretary’s redetermination is due on notice and demand. I.R.C. sec.…