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deficiency has been issued and the taxpayer has petitioned
for review, section 6512(a) provides that the Tax Court
should be able to determine an overpayment to the exclusion
of the other tax forums. Id. at 451-452. We noted that
this intent would be frustrated by reading section 6512(b)
to provide that the overpayments which are the subject of
the Tax Court’s jurisdiction are substantially different
from the overpayments which are subject to the jurisdiction
of the other tax forums. Id. at 451. Stated differently,
we noted that the “overpayment” determined by the Tax Court
should be synonymous with that determined by a U.S.
District Court or the Court of Federal Claims. We further
noted that:
With respect to interest which is part of an
overpayment, * * * we must be able to determine
all components of that overpayment or a taxpayer
unwittingly may not be able to recover interest
in those situations where the Commissioner
initially determined a deficiency and the
taxpayer petitioned to the Tax Court. * * *
Id. at 453.
In Estate of Baumgardner v. Commissioner, 85 T.C. 445
(1985), we overruled two Opinions of the Court which had
held that the words “an overpayment of tax”, in the
predecessor of section 6512(b), excluded interest. Id. at
456. In discussing those Opinions, we said the following:
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