OPINION
FEATHERSTON, Judge:
Respondent determined a deficiency in the amount of $3,874.84 in petitioner's Federal income tax for 1969. The issue here involves the procedure to be followed by the Internal Revenue Service in recovering a credit tentatively allowed as a carryback adjustment in respect of petitioner's joint return for 1969, applied on an unpaid employment tax penalty liability of her husband, and later shown by an audit to have been erroneous...
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