“Did the lower court commit clear error where it determined that a taxpayer’s signature on a tax return is a Congressional mandate to which the doctrine of waiver does not apply?”
“Did the lower court commit reversible error when it dismissed Appellants’ case for lack of subject matter jurisdiction?”
Holding
“Because the taxpayer signature and verification requirements derive from statute, the IRS cannot waive those requirements.”
“While we disagree that the court lacked jurisdiction, we nonetheless affirm because the court was correct that the Browns failed to prove that their claim for refund was duly filed.”
