On August 11, 2021, the Tax Court issued a Memorandum Opinion in the case of Mohsen v. Commissioner (T.C. Memo. 2021-99). The primary issues presented in Mohsen v. Commissioner were whether the Tax Court possessed jurisdiction to decide the taxpayer’s claim for refund and whether the taxpayer’s unpaid income tax liability could be offset by a claimed (time-barred) credit. Filing Background to Mohsen v. Commissioner On April 15, 2002, the petitioner mailed the IRS a