- 23 -
of the items treated as overpayments by section 6401(a)),
affd. without published opinion 172 F.3d 859 (3d Cir.
1998); Barton v. Commissioner, 97 T.C. 548, 555 (1991)
(increased interest (at 120 percent of the normal rate)
governed by section 6621(c) is part of an overpayment);
Estate of Bell v. Commissioner, 92 T.C. 714, 728 (1989),
(an estate which elected to defer estate tax under section
6166 is entitled to a determination of the overpayment of
interest, as well as a determination of the overpayment
of tax), affd. 928 F.2d 901 (9th Cir. 1991); Judge v.
Commissioner, 88 T.C. 1175, 1187 (1987) (the additions
to tax under section 6651(a)(1) and (2) are part of an
overpayment); Gabelman v. Commissioner, T.C. Memo. 1993-592
(section 6512(b) confers jurisdiction on this Court to
review the amount of an overpayment of tax, including
amounts withheld from the taxpayer’s wages), affd. 86 F.3d
609 (6th Cir. 1996); Johnson v. Commissioner, T.C. Memo.
1993-562 (a deposit is not a payment, and thus this Court
lacks jurisdiction under section 6512(b) to order a refund
of any part of such an amount); see also Bankamerica Corp.
v. Commissioner, 109 T.C. 1 (1997); Centel Communications
Co. v. Commissioner, 92 T.C. 612, 628 (1989), affd. 920
F.2d 1335 (7th Cir. 1990); 508 Clinton Street Corp. v.
Commissioner, 89 T.C. 352, 354 (1987); Pace v. Commis-
Page: Previous 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 NextLast modified: May 25, 2011