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          doctrine of equitable recoupment is a judicially created doctrine           
          that precludes the unjust enrichment of a party to a lawsuit and            
          avoids a wasteful multiplicity of litigation.  See Estate of                
          Mueller v. Commissioner, supra at 551-552.  As applied for the              
          benefit of a taxpayer, the doctrine provides that, in some cases,           
          a claim for a refund of taxes barred by a statute of limitations            
          may, nevertheless, be recouped against a tax claim of the                   
          Government.  See Bull v. United States, 295 U.S. 247, 258-263               
          (1935).  Equitable recoupment is in the nature of a defense                 
          arising out of some feature of the transaction upon which the               
          claim for taxes is grounded.  See id. at 262.  The doctrine is              
          applied only where a single transaction constitutes the taxable             
          event claimed upon and the one considered in recoupment.  See               
          Rothensies v. Electric Storage Battery Co., 329 U.S. 296, 299-300           
               Recently, we listed the elements necessary to sustain the              
          defense of equitable recoupment:                                            
                    A claim of equitable recoupment requires: (1) That                
               the refund or deficiency for which recoupment is sought                
               by way of offset be barred by time; (2) that the                       
               time-barred offset arise out of the same transaction,                  
               item, or taxable event as the overpayment or deficiency                
               before the Court; (3) that the transaction, item, or                   
               taxable event have been inconsistently subjected to two                
               taxes; and (4) that if the subject transaction, item,                  
               or taxable event involves two or more taxpayers, there                 
               be sufficient identity of interest between the                         
               taxpayers subject to the two taxes so that the                         
               taxpayers should be treated as one.                                    
                    * * *                                                             
          Estate of Branson v. Commissioner, supra at ___ (slip op. at 15).           
          III.  Analysis                                                              

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