(1) Any refund that is erroneously paid shall be considered an underpayment of the tax liability and may be assessed and collected in the same manner as any other underpayment of the tax required to be paid. (2) It shall be an underpayment as of the date of the payment of the refund, the date the refund was applied to another liability, or the date the credit was used by the taxpayer to satisfy a subsequent tax liability.
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