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parties filed a stipulation of settled issues to that effect.
Petitioner also concedes that respondent was authorized to apply
the $10,131 overpayment that petitioner claimed on his 1993
return to his 1990 and 1991 taxable years. Petitioner contends
that respondent improperly determined petitioner's tax
liabilities--specifically interest and penalties--for 1990 and
1991. Thus, according to petitioner, some portion of the $10,131
overpayment is now available as an offset against the agreed
deficiency for 1993.
OPINION
This Court is a court of limited jurisdiction; accordingly,
we may only exercise jurisdiction to the extent expressly
permitted or provided by statute. Henry Randolph Consulting v.
Commissioner, 112 T.C. ___, ___ (1999) (slip op. at 6); Trost v.
Commissioner, 95 T.C. 560, 565 (1990); Judge v. Commissioner, 88
T.C. 1175, 1180-1181 (1987). Thus, we have jurisdiction to
redetermine a deficiency if a valid notice of deficiency is
issued by the Commissioner and if a timely petition is filed by
the taxpayer. Rule 13(a), (c); Monge v. Commissioner, 93 T.C.
22, 27 (1989); Normac, Inc. v. Commissioner, 90 T.C. 142, 147
(1988). Insofar as our jurisdiction regarding overpayments is
concerned, section 6512(b)(1) provides:
if the Tax Court finds that there is no deficiency and
further finds that the taxpayer has made an overpayment
of income tax for the same taxable year, * * * or finds
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