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petitioner did not file a timely formal refund claim, we must
conclude that petitioner has failed to prove that he filed a
qualifying refund claim as required by section 6512(b)(3)(C)(i).
Consequently, we hold that petitioner is not entitled to a refund
of his overpayments for 1993 and 1994 under section
6512(b)(3)(C)(i).
We have considered the other arguments of the parties and,
to the extent not discussed above, we conclude that the arguments
are irrelevant, moot, or meritless.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011