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the 2-year "look-back period" prior to the date of the mailing of
the notice of deficiency, as prescribed by section 6511(b)(2)(B).
Id.
Pursuant to section 6512(b)(3)(B), petitioner is deemed to
have filed a claim for credit or refund on May 18, 1994, the date
the notices of deficiency were mailed. Accordingly, under the 2-
year look-back period of section 6511(b)(2)(B), petitioner would
be entitled to a refund of any overpayments of her tax made on or
after May 18, 1992, for tax years 1990 and 1991. However,
because section 6513(b)(1) deems the tax withheld from
petitioner's wages during 1990 and 1991 to have been paid on
April 15, 1991 and April 15, 1992, respectively, no portion of
the tax was paid during the 2-year look-back period.
Consequently, we must hold that petitioner is not entitled
to a decision that she has an overpayment of her 1990 or 1991
Federal income tax, and, hence, no portion of the amounts
withheld from petitioner's wages during 1990 and 1991 may be
refunded or credited as an overpayment. Petitioner made no
payments during the 2-year look-back period preceding the date
the statutory notices of deficiencies were mailed, and she is
barred by section 6511(b)(2)(B) from obtaining any portion of her
1990 or 1991 overpayments. Although this result may seem harsh,
it follows directly from petitioner's failure, through her own
neglect, to fulfill her obligations to file a timely return or
otherwise to exercise her rights within the time period
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