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respondent. See secs. 6213 and 6214; Murphree v. Commissioner,
87 T.C. 1309, 1311 (1986); see also sec. 6211 (meaning of the
word "deficiency"). When respondent has not determined a
deficiency for a year, we generally may not redetermine if a
deficiency or overpayment is present for that year. See sec.
6214(b) ("The Tax Court in redetermining a deficiency * * * shall
have no jurisdiction to determine whether or not the tax for any
other year or calendar quarter has been overpaid or underpaid");
see also Rothensies v. Electric Storage Battery Co., 329 U.S. 296
(1946); Commissioner v. Gooch Milling & Elevator Co., 320 U.S.
418 (1943); Hays v. Commissioner, T.C. Memo. 1996-18; Warden v.
Commissioner, T.C. Memo. 1990-321, affd. without published
opinion sub nom. Beam v. Commissioner, 956 F.2d 1166 (9th Cir.
1992); Stowman v. Commissioner, T.C. Memo. 1983-235; Hutchinson
v. Commissioner, T.C. Memo. 1980-551.
In the instant case, respondent has determined a deficiency
for 1990, and petitioner's 1990 taxable year is the only year
that is before the Court. Thus, even if petitioner did overpay
his 1989 tax, a matter on which we express no opinion, we would
lack jurisdiction to apply that overpayment against petitioner's
deficiency for 1990.
We have considered all arguments made by petitioner for a
contrary holding, and, to the extent not addressed above, find
them to be without merit. To reflect respondent's concessions,
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