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In the case at hand, petitioner contends the deficiency
procedures are not available to respondent to recover the
tentative refunds on the ground that they are nonrebate refunds
because petitioner, as the former common parent, was an
“unauthorized recipient”.
Contrary to petitioner’s suggestion otherwise, respondent
was not sure who the “authorized representative” of the
affiliated group was when he paid the tentative refunds and was
not required to undertake to decide that question prior to paying
the tentative refunds. We therefore disagree that the tentative
refunds were paid to petitioner because of any mistake by
respondent that would give rise to petitioner’s receipt of a
nonrebate refund.
When the Commissioner receives an application for tentative
carryback adjustment, he is required within a 90-day period to
undertake a “limited examination” of the application. Sec.
6411(b). During the limited examination, the Commissioner is
expected to uncover ministerial and computational errors and
omissions. The limited examination is not designed to provide a
thorough review of all of the facts and statutory and regulatory
provisions pertaining to the taxpayer’s right to the refund.
Polachek v. Commissioner, 22 T.C. 858, 863-865 (1954). The
review of the facts and relevant statutory and regulatory
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