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99-3323 Malachinski v. Commissioner of Internal Revenue

"Even if Dr. Malachinski's remittance could be considered a payment rather than a deposit when it was transferred and credited to his 1982 account, sec. 6512(b)(4) nevertheless prevents the tax court from exercising jurisdiction over the remittance. ... The Senate Report explains that ... 'the Tax Court does not have jurisdiction over the validity or ...

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