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If petitioners had contended that an overpayment exists in
the instant case due to the February 12, 1999, remittances, this
Court would have jurisdiction to decide whether they should be
treated as payments of the deficiencies in issue. Sec.
6512(b)(1); see Naftel v. Commissioner, 85 T.C. 527 (1985); see
also Baumgardner v. Commissioner, 85 T.C. 445 (1985); Keefe v.
Commissioner, 15 T.C. 947 (1950). Thus our overpayment
jurisdiction is not invoked.
On the basis of the foregoing, we will enter a decision for
respondent with respect to the deficiencies in issue without any
statement as to whether those deficiencies have been paid.7
We have considered all of the contentions of the parties
that are not discussed herein, and we find them to be without
merit, irrelevant, or moot.
To reflect the foregoing,
Decision will be entered
for respondent.
7We note that this Court might have jurisdiction under secs.
6320 and 6330 to decide whether the Feb. 12, 1999, remittances
paid the deficiencies in issue, but that jurisdiction has not
been invoked in the instant case.
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