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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 taxes
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