-10-
S. Ct. 647, 652-653 (1996); Rossman v. Commissioner, 46 F.3d 1144
(9th Cir. 1995), affg. without published opinion T.C. Memo. 1993-
351; Richards v. Commissioner, 37 F.3d 587 (10th Cir. 1994), affg.
T.C. Memo. 1993-102; Allen v. Commissioner, 23 F.3d 406 (6th Cir.
1994), affg. without published opinion 99 T.C. 475 (1992); Davison
v. Commissioner, 9 F.3d 1538 (2d Cir. 1993), affg. without
published opinion T.C. Memo. 1992-709; Galuska v. Commissioner, 5
F.3d 195 (7th Cir. 1993), affg. 98 T.C. 661 (1992); Patronik-Holder
6(...continued)
refund shall be allowed or made of any portion of the tax
unless the Tax Court determines as part of its decision that
such portion was paid--
(A) After the mailing of the notice of deficiency,
(B) Within the period which would be applicable
under section 6511(b)(2), (c), or (d), if on the date of
the mailing of the notice of deficiency a claim had been
filed (whether or not filed) stating the grounds upon which
the Tax Court finds that there is an overpayment, or
(C) Within the period which would be applicable
under section 6511(b)(2), (c), or (d), in respect of any
claim for refund filed within the applicable period
specified in section 6511 and before the date of the
mailing of the notice of deficiency--
(i) which had not been disallowed
before that date,
(ii) which had been disallowed before
that date and in respect of which a
timely suit for refund could have been
commenced as of that date, or
(iii) in respect of which a suit for
refund had been commenced before that
date and within the period specified in
section 6532.
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