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petition with this Court. There is no doubt that we have
jurisdiction of this case. We may therefore exercise full
judicial power in its disposition.
Court of Appeals for the Ninth Circuit
Any appeal in this case lies to the Court of Appeals for the
Ninth Circuit, and we are bound by any decision of that court
squarely in point. See Golsen v. Commissioner, 54 T.C. 742, 756-
757 (1970), affd. 445 F.2d 985 (10th Cir. 1971). Respondent
asserts that this issue was settled in the Ninth Circuit by
Mohawk Petroleum Co. v. Commissioner, 148 F.2d 957, 959 (9th Cir.
1945), affg. 47 B.T.A. 952 (1942).
In Mohawk Petroleum Co. v. Commissioner, supra, the Court of
Appeals relied on Gooch Milling & Elevator Co. for its decision
that the Board of Tax Appeals lacked jurisdiction to consider
equitable recoupment of income taxes. See id. at 959. Because
we have found that Gooch Milling & Elevator Co. is not on point,
it follows that Mohawk Petroleum Co. is not dispositive.
Accordingly, we disagree with respondent's assertion.
In Mueller II, we found additional support for our decision
in sections 7422(e), 6512(a), and 7481. See Mueller II, 101 T.C.
at 557. Considered together, these sections indicate that
"Congress intended the Tax Court to have full judicial authority
to resolve issues over which it has jurisdiction". Woods v.
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