An interesting Tax Court case, where the taxpayer argued that an amount due to the taxpayer should have accrued overpayment interest to be included in the refund. The court recognized that there is a distinction between payments and deposits when it comes to accruing interest. The taxpayer argued in part that although described as a deposit, the amount paid in was treated by the IRS as a payment - because it was not returned on request. However, the IRS cited an exception to the "return on request" rule for deposits, when collection in jeopardy. Application of the exception to these facts looked strange, but the court accepted it. The taxpayer also would have lost because the parties agreed that there was a payment greater than the amount of the deficiency, but the law requires a determination by the court of an overpayment - and the court made no such determination.