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amended 1996 return that her prepayment credits for 1996 total
$30,480).
In Millsap v. Commissioner, supra, we held that substitute
for returns prepared by the Commissioner pursuant to section
6020(b)(1) do not constitute separate returns for purposes of
section 6013(b), even though section 6020(b)(2) literally treats
such returns as “prima facie good and sufficient for all legal
purposes.”
We hold that the 2-year look-back period in section
6511(b)(2)(B) applies for purposes of section 6512(b)(3)(B). We
further hold that petitioner is not entitled to a refund of her
1996 overpayment.4 See sec. 6512(b)(3)(B); Commissioner v.
Lundy, 516 U.S. 235 (1996).
To reflect the foregoing,
Decision will be entered under
Rule 155.
4We have considered all of the contentions and arguments of
petitioner that are not discussed herein, and we find them to be
without merit and/or irrelevant.
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