OPINION
NICHOLS, Judge.
Plaintiff, a corporate taxpayer, sues for interest on its overpayment of estimated tax which, at taxpayer's election, was credited against installments of estimated tax for the succeeding tax year. The facts are before the court on stipulation of the parties, reported by our commissioner pursuant to Rule 134(b).
Although there are several years at issue here, the fact pattern is the same for each year. Plaintiff pays its tax...
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