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2 years. Petitioner argues that 100 percent of the overpayments
were attributable to worthless debts or worthless securities,
which makes them refundable in full under the 7-year rule of
section 6511(d)(1). Petitioner alleges in his brief that the
overpayments were attributable to debts and securities which were
worthless, and he attached certain documents to his brief which
he claims support his allegation. Petitioner argues that each
"return" prepared by respondent under section 6020(b) was a
return for purposes of section 6511, and he contends in his brief
that respondent prepared the returns on August 4, 1994.
Petitioner contends in his brief that respondent offered him a
settlement under which he would have been allowed the 1986
overpayment in full, and he argues that the respondent's offer
proves his right to the 1986 refund.
We hold for respondent. Petitioner must prove that the
disputed amounts were attributable to worthless debts or
worthless securities, Welch v. Helvering, 290 U.S. 111, 115
(1933); see also Borchers v. Commissioner, 95 T.C. 82, 91 (1990)
(fact that case submitted to the Court fully stipulated under
Rule 122 does not change or otherwise lessen taxpayer's burden),
affd. 943 F.2d 22 (8th Cir. 1991); Drum v. Commissioner, T.C.
Memo. 1994-433 (same), affd. without published opinion 61 F.3d
910 (9th Cir. 1995), and petitioner must demonstrate that his
claim for refund was timely, Michelson v. Commissioner, T.C.
Memo. 1997-39. Although section 6512(b)(1) bestows jurisdiction
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