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that a claim for refund was made within the time frame provided
under section 6511.
Based on the foregoing, we sustain respondent’s
determination, and petitioner is not entitled to relief since any
refund of payments with respect to the 1979 tax year is barred
under section 6511.
To give effect to the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011