MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge:
Petitioner petitioned the Court to redetermine respondent's determination of a $17,287 deficiency in his 1990 Federal income tax and a $4,297 addition thereto under section 6651(a)(1). Following concessions, the only issue left to decide is whether we are authorized to determine any overpayment from 1989 that petitioner may credit to his 1990 Federal income tax liability. We hold we are not. Section references...
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