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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 the instant cases, respondent is attempting to collect
alleged erroneous refunds resulting from the trusts’ alleged
overstatements 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
provide the taxpayer no right to petition the Tax Court to
contest the liability. See sec. 6213(b)(1).7
7 Sec. 6213(b)(1) provides:
If the taxpayer is notified that, on account of a
mathematical or clerical error appearing on the
return, an amount of tax in excess of that shown
on the return is due, and that an assessment of
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