Already Graded A
Overview of GI
If the IRS asserts person has a tax deficiency he or she may
1. Refuse to pay and petition the Tax Court for a redetermination of the deficiency or
2. Pay the deficiency, file an administrative claim for refund, and upon denial of the
claim, sue for a refund in federal district court or the US court of federal claims.
US District Court
• After deficiency payment
• May be jury
• Where taxpayer resides
• Refund action
United States Court of Federal Claims
• After deficiency payment
• Federal Courts Improvement Tax of 1982
• No jury
• Doesn't matter where you reside
• Principle headquarters D.C.
Appellate Courts
• Circuit where person resides
• U.S. COA for federal circuit
Gross income
• §1.6(a)1 - includes income realized in any form whether money, property, or services
• §61 except otherwise provided in this subtitle, gross income means all income from
whatever source derived, including (but not limited to)
Adjusted Gross Income
§62 gross income less certain deductions
Deductions Above the line
o Must determine in figuring out AGI
o Business expenses
Deductions Below the line