- 14 -
In conclusion, we are satisfied that respondent has not
assessed, and is not attempting to collect, the deficiency for
1990 in dispute in this case. Because we lack the authority to
bar collection under the circumstances presented, we will deny
petitioners' motion to restrain collection as supplemented.
To reflect the foregoing,
An order will be entered
denying petitioners' motion to
restrain collection as
supplemented.
4(...continued)
allegations invoking the Court's jurisdiction to determine an
overpayment pursuant to sec. 6512(b). See, e.g., Dover Corp. v.
Commissioner, T.C. Memo. 1997-339, affd. per curiam F.3d ___
(2d Cir., June 4, 1998).
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