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overpayment. Moreover, the Supreme Court has recently reiterated
that the provisions of section 6511, establishing the period of
limitations for recovering overpayments, are to be strictly
construed, see United States v. Brockamp, 519 U.S. 347, 352-354
(1997), and Congress, after recently scrutinizing section 6511,
has seen fit to change it only in circumstances for which
petitioner would not qualify. See sec. 6511(h), enacted by
Internal Revenue Service Restructuring and Reform Act of 1998
(RRA 1998), Pub. L. 105-206, sec. 3202(a), 112 Stat. 740
(relaxation of limitations period where taxpayer physically or
mentally impaired); sec. 6512(b)(3), amended by Taxpayer Relief
Act of 1997, Pub. L. 105-34, sec. 1282(a), 111 Stat. 1037 (3-
rather than 2-year “look-back” period where no return filed and
deficiency notice issued in third year after return due).
A second allegation made by petitioner is that respondent
acted improperly in this case by asserting deficiencies for 1995
and 1996 that he knew or should have known were far in excess of
what petitioner rightfully owed and then sought to use the Tax
Court process to “extort” money from petitioner.
Our review of the entire record in this case does not
indicate that respondent has acted improperly. We see nothing
improper in the original deficiency determinations. Petitioner
was treated the same as any nonfiler: respondent computed the
deficiencies based on information returns from third parties and
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