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Pursuant to the authority conferred by section 6402(a),
respondent credited $67,078 of the overpayment by petitioner of
his 1973 taxes against his assessed and unpaid tax liability for
1975. Petitioner contends that respondent did not apply the
overpayment according to his instructions in the December 1988
letter. However, section 6512(b)(4) clearly restricts the
jurisdiction of this Court to decide that matter because that
would constitute a review of a credit made under section 6402.
Our holding in this case is consistent with our holding in
Winn-Dixie Stores, Inc. v. Commissioner, 110 T.C. 291 (1998). In
that case, the taxpayer agreed to the Commissioner's
determination for certain years before the Court (the present
years' underpayments). The Commissioner and the taxpayer also
agreed as to the overpayments for certain years not before the
Court (the prior years' overpayments). The taxpayer requested
that the Commissioner offset the prior years' overpayments
against the present years' underpayments. However, the
Commissioner refunded to the taxpayer the prior years'
overpayments, including interest thereon calculated at the
overpayment rate under section 6621(a)(1). The Commissioner
later mailed notices of tax due, including interest calculated at
the underpayment rate under section 6621(a)(2) and (c), for the
present years' underpayments. The taxpayer paid the present
years' underpayments, together with interest at the underpayment
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