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1983 and 1984 under section 6013(e) because her pre-September 5,
1997, letters were not part of a deficiency case in this Court.
Respondent concedes that Kohl’s February 5, 1996, letter, is
a claim for an $8,874 refund for 1983 based on income averaging.
Kohl’s February 5, 1996, letter discussed only income averaging
for 1983; it is not a claim for refund of taxes based on section
6015.
We conclude that letters petitioner and Kohl sent to
respondent before September 5, 1997, do not constitute a claim
for refund of taxes paid for 1983 and 1984 based on section 6015.
C. Whether Letters Petitioner Sent to Respondent After March
15, 1999, Were Timely Refund Claims for Taxes She Paid
Relating to Robotics for 1983 and 1984
1. Time Limits for Refund Claims Under Section 6015(f)
A taxpayer may be entitled to a refund if relief is granted
under section 6015(f). Sec. 6015(g)(1). The time limits for
requesting a refund provided by section 6511 apply to refunds
sought under section 6015(f). Sec. 6015(g)(1). We next consider
whether the letters petitioner sent to respondent after March 15,
1999, constitute a timely refund claim under section 6511.
A taxpayer may obtain a refund of overpaid tax if he or she
files a claim for refund within 3 years from the time the return
was filed or 2 years from the time the tax was paid, whichever is
later. Sec. 6511(a). Petitioner paid tax of $7,565 for 1983 on
September 5, 1995, and $1,996 for 1984 on September 6, 1995, and
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