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(2) They assert that three of the deficiency notices are
untimely. This contention is directly contrary to the
stipulation of settled issues and, accordingly, is rejected.
(3) They seek to have us reopen years prior to 1985 in
order to give petitioners the benefit for those years of what
they claim is more favorable treatment in the stipulation of
settled issues for the years before us. We reject this attempt
for the simple reason that, in the apparent absence of any
pending deficiency notices and petitions for the earlier years,
we are without jurisdiction to deal with petitioners' assertions.
We note in passing that it would appear that the period of
limitations has long since expired in respect of any overpayments
of taxes for those earlier years.
(4) They seek to have us deal with levies and liens in
respect of matters not involved in this proceeding and apparently
relating to the windfall profit excise taxes for other years, in
particular 1980. Here again, we are without jurisdiction in
respect of any such levies or liens. Beyond this, we have no
jurisdiction in respect of a year not before us3 or in respect of
3 Sec. 6214(b) provides that we:
shall consider such facts with relation to the taxes
for other years or calendar quarters as may be
necessary correctly to redetermine the amount of such
deficiency, but in so doing shall have no jurisdiction
to determine whether or not the tax for any other year
or calendar quarter has been overpaid or underpaid.
(continued...)
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