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alternatively, that the Court enter a decision in the form
prepared by respondent but also separately order respondent to
apply $67,078 of petitioner's 1973 overpayment to petitioner's
1980 tax deficiency.
This Court is a court of limited jurisdiction; accordingly,
the Court may only exercise jurisdiction to the extent expressly
permitted or provided by statute. See Trost v. Commissioner, 95
T.C. 560, 565 (1990); Judge v. Commissioner, 88 T.C. 1175, 1180-
1181 (1987). Thus, this Court has jurisdiction to redetermine a
deficiency if a notice of deficiency is issued by the
Commissioner and if a petition is filed timely by the taxpayer.
See Rule 13(a), (c); Monge v. Commissioner, 93 T.C. 22, 27
(1989); Normac, Inc. v. Commissioner, 90 T.C. 142, 147 (1988).
Respondent issued a valid notice of deficiency, and
petitioner filed a timely petition; therefore, this Court has
jurisdiction to redetermine the deficiency or to determine an
overpayment for each of the years at issue. The parties have
agreed to the amounts of the deficiencies, the additions to tax,
and increased interest. Petitioner has not and does not now
claim an overpayment for either year at issue. Instead,
petitioner contends that his return of the refund check was a
deposit in the nature of a cash bond to be applied or credited to
his 1980 tax liability, and that respondent did not properly
apply the deposit in accordance with petitioner's instructions in
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