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his overpayment is the direct result of his failure to file a
return and pursuant to the application of the above-described
provisions of the Internal Revenue Code.
We therefore hold that the statutorily imposed time
limitations of sections 6511 and 6512 bar us from determining
that petitioner is entitled to a refund with respect to his 1999
tax. See Commissioner v. Lundy, supra; Badger v. Commissioner,
T.C. Memo. 1996-314; Stevens v. Commissioner, supra.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
Decision will be entered
for respondent as to the
deficiency in the amount of
$9,344 and for respondent as
to the overpayment.
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