MEMORANDUM OPINION
TANNENWALD, Judge:
This matter is before the Court on respondent's motion for leave to file an amendment to answer in which she seeks to recover an asserted erroneous refund.
Petitioner and her husband obtained extensions of time to file their joint Federal income tax return for the taxable year 1991 until October 15, 1992. Petitioner and her husband made payments regarding their 1991 tax liability as follows:
Type...
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