Cite as: 528 U. S. 431 (2000)
Opinion of the Court
amounts withheld from wages "shall be allowed to the recipient of the income as a credit against the [income] tax," and § 6315 states that "[p]ayment of the estimated income tax, or any installment thereof, shall be considered payment on account of the income taxes imposed by subtitle A for the taxable year." Similarly, one of the regulations cited by Baral explains that a remittance of estimated income tax "shall be considered payment on account of the income tax for the taxable year for which the estimate is made." 26 CFR § 301.6315-1 (1999) (emphasis added). Baral's reading fails, moreover, to give any meaning to 26 U. S. C. § 6513. That section exists "[f]or purposes of section 6511," and § 6511 concerns credits and refunds, which result only when the aggregate of remittances (such as withholding tax and estimated income tax) exceed the tax liability, see § 6401. Thus, the concepts of credit or refund have no meaning as applied to Baral's notion of withholding taxes and estimated taxes as freestanding taxes. Not surprisingly, the caption to § 6513(b) describes withholding and estimated income tax remittances as "[p]repaid income tax."
Taking a more metaphysical tack, Baral contends that income tax is "paid" under § 6511(b)(2)(A) only when the income tax is assessed—here, June 1 or July 19, 1993, see supra, at 434-435—because the concept of payment makes sense only when the liability is "defined, known, and fixed by assessment," Brief for Petitioner 9. But the Code directly contradicts the notion that payment may not occur before assessment. See § 6151(a) ("[T]he person required to make [a return of tax] shall, without assessment or notice and demand from the Secretary, pay such tax . . . at the time and place fixed for filing the return" (emphasis added)); § 6213(b)(4) ("Any amount paid as a tax or in respect of a tax may be assessed upon the receipt of such payment" (emphasis added)). Nor does Baral's argument find support in our decision in Rosenman v. United States, 323 U. S. 658 (1945), where we applied § 6511's predecessor to a remittance of esti-
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