MEMORANDUM AND ORDER
FULLAM, District Judge.
Section 6402 of the Internal Revenue Code deals with refunds to taxpayers of amounts paid to IRS in excess of tax due. Subsection (a) provides the general rule that the balance of the overpayment is to be refunded to the taxpayer. Subsection (b) provides for optional credit of such overpayments against estimates of future taxes. In 1981, subsection (c) was added, in conjunction with amendments to § 6305 of...
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