Crew III, J.
The relevant facts are not disputed by the parties. In March 1983, petitioner applied to the Internal Revenue Service (hereinafter IRS) for a tentative refund of Federal income tax for tax years ending December 31, 1979 and December 31, 1982. Petitioner's claim for a refund with respect to the tax year ending December 31, 1979 was based upon the carryback of a net operating loss sustained in 1982. Thereafter, in April 1983, petitioner received payment...
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