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requirement that a notice of deficiency be signed. Everman v.
Commissioner, supra. We, therefore, find petitioner’s argument
to be similarly meritless and conclude that petitioner is liable
for the deficiencies respondent determined in the notices of
deficiency for the years in issue.
II. Refund for 2000 Taxable Year
Petitioner also argued that the “refund” requested on his
2000 tax return was incorrectly applied to the tax liabilities
for 2000 rather than being refunded to him. We disagree.
We do not find that petitioner made an overpayment in 2000
that should be refunded to him. In general, if a taxpayer has
made an “overpayment” and the overpayment is not applied against
any of the taxpayer’s outstanding tax liabilities, the Secretary
must refund the payment, including interest. Sec. 6402(a);
Bachner v. Commissioner, 109 T.C. 125, 128 (1997), affd. without
published opinion 172 F.3d 859 (3d Cir. 1998). Section 6512(b)
gives the Court jurisdiction to determine the amount of any
overpayment to be credited or refunded where we have jurisdiction
to redetermine a deficiency. Bachner v. Commissioner, supra at
128.
We look to caselaw to define “overpayment” because there is
no specific definition of the term “overpayment” in the Code
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