MEMORANDUM OPINION
GALE, Judge:
Respondent determined the following deficiencies in petitioner's Federal income tax:
Year Deficiency 1988 $9,866 1989 1,612 1991 414
We must decide the following:
1. Whether the limitations period for assessing taxes for the years 1988 and 1989 has expired. We hold that it has not.
2. Whether petitioner has made overpayments with respect to 1988 and...
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