- 5 - (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...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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