- 99 -
deficiency resulting from our application of equitable
recoupment, which can't exceed the amount of that deficiency.
I would find that respondent's overpayment argument doesn't
prevent the application of equitable recoupment. This would
allow us to consider all the other issues, on which I would also
find in favor of petitioner. Consequently, I would apply
equitable recoupment in favor of petitioner.
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