discussed Cited "see, e.g." John A. Zeier v. United States Internal Revenue Service See Ehle, 720 F.2d at 1096-97 (remittances without assessment constitute tax payments, not deposits); see also Jones v. Liberty Glass Co., 332 U.S. 524, 531-2 , 68 S.Ct. 229, 232-33 , 92 L.Ed. 142 (1947), reh'g denied, 333 U.S. 850 , 68 S.Ct. 657 , 92 L.Ed. 1132 (1948)(remittances in excess of what is due are overpayments); 26 U.S.C. § 6401 (c); S. Rep. 221, 78th Cong., 1st Sess. at 34-5 (1943)(remittance made when there is no tax liability constitutes overpayment).EQUITABLE TOLLING 27 This court in Brockamp v. U.S. has determined that "the statute of limitations in § 6511 may be equitably t…

discussed Cited "see, e.g." Zeier v. United States Internal Revenue Service See Ehle, 720 F.2d at 1096-97 (remittances without assessment constitute tax payments, not deposits); see also Jones v. Liberty Glass Co., 332 U.S. 524, 531-2 , 68 S.Ct. 229, 232-33 , 92 L.Ed. 142 (1947), reh’g denied, 333 U.S. 850 , 68 S.Ct. 657 , 92 L.Ed. 1132 (1948)(remit-tances in excess of what is due are overpayments); 26 U.S.C. § 6401 (c); S. Rep. 221, 78th Cong., 1st Sess. at 34-5 (1943)(remit-tanee made when there is no tax liability constitutes overpayment).