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(1998). The filing of a timely petition in this Court
in response to a notice of deficiency gives the Court
exclusive jurisdiction and precludes the taxpayer from
later bringing a refund suit for the same type of tax for
the same taxable period. Sec. 6512(a); see Estate of
Ming v. Commissioner, 62 T.C. 519, 521 (1974); Dorl v.
Commissioner, 57 T.C. 720 (1972), affd. 507 F.2d 406 (2d
Cir. 1974).
Respondent issued a notice of deficiency to
petitioner for the years in issue, and petitioner invoked
our deficiency jurisdiction by filing a timely petition.
In the pleadings, petitioner asserts that there is no
deficiency in any of the years in issue, and it claims an
overpayment for each of those years. As mentioned above,
petitioner’s overpayment claims include overpayments
consisting in part of interest respondent computed on the
interim underpayment balances reflected in petitioner’s
account, so-called underpayment interest. Petitioner
contends that the amounts of underpayment interest
respondent computed are too high. Petitioner’s overpayment
claims also include overpayments consisting in part of
interest computed on the interim overpayment balances
reflected in petitioner’s account, so-called overpayment
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