- 8 - also Estate of Meyer v. Commissioner, 84 T.C. 560, 562 (1985); Adams v. Commissioner, 72 T.C. 81, 84 (1979), affd. without published opinion 688 F.2d 815 (2d Cir. 1982). With exceptions not germane here, this Court’s jurisdiction is generally limited to redetermining deficiencies in income taxes, estate and gift taxes, and certain specified excise taxes that are subject to the deficiency procedures outlined above. See secs. 6214, 7442; see also Estate of Meyer v. Commissioner, supra at 562; Judd v. Commissioner, 74 T.C. 651, 653 (1980). In this case, respondent is attempting to collect an alleged erroneous refund resulting from petitioner’s alleged overstatement of income taxes withheld. The assessments at issue were not subject to the deficiency procedures but instead were subject to the summary assessment procedures of section 6201(a)(3). Under those procedures, overstatements of withheld income taxes are generally treated in the same manner as mathematical or clerical errors appearing on the return, except that in the case of an assessment of an overstated credit for withholding, the taxpayer has no right to request an abatement. See secs. 6201(a)(3), 6213(b)(1) and (2). Therefore, summary assessments with respect to overstatements of withheld taxesPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
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