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outstanding liability for 1995 representing an assessment for
failure to file and failure to pay additions to tax as well as
interest.
For the foregoing reasons, we hold that our jurisdiction
under section 6330(d)(1)(A) encompasses consideration of facts
and issues in nondetermination years where the facts and issues
are relevant in evaluating a claim that an unpaid tax has been
paid.
In reaching this conclusion, we are mindful that in the case
of our deficiency jurisdiction, section 6214(b) imposes
limitations on our jurisdiction with respect to years other than
the year for which a deficiency has been determined. Section
6214(b) provides that, in redetermining a deficiency of income
tax for any taxable year, this Court "shall consider such facts
with relation to the taxes for other years * * * as may be
necessary correctly to redetermine the amount of such deficiency,
but in so doing shall have no jurisdiction to determine whether
or not the tax for any other year * * * has been overpaid or
underpaid." In interpreting this provision--
We have distinguished our authority under section
6214(b) to compute a tax for a year not before the
Court from our lack of authority under that same
section to "determine" a tax for such year. In Lone
Manor Farms, Inc. v. Commissioner, 61 T.C. 436, 440
(1974), affd. without published opinion 510 F.2d 970
(3d Cir. 1975), we stated that section 6214(b) "does
not prevent us from computing, as distinguished from
'determining', the correct tax liability for a year not
in issue when such a computation is necessary to a
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