Doreen Boyd - Page 9

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          obligation to apply any or all of petitioner’s refunds solely               
          against petitioner’s liabilities for the years in issue.                    
               Further, pursuant to section 6512(b)(4), this Court is                 
          restricted from restraining or reviewing any credit or reduction            
          made by respondent under section 6402.  See Savage v.                       
          Commissioner, 112 T.C. 46 (1999).  Therefore, we are without                
          jurisdiction to decide whether respondent improperly credited any           
          overpayments to petitioner’s tax liabilities for years not before           
          the Court.  See id.                                                         
               Finally, petitioner’s allegation that respondent erroneously           
          denied her earned income credits for subsequent tax years does              
          not present a cognizable claim under section 6404(a) or (e).  We            
          must assume that petitioner’s contention is that respondent                 
          improperly determined her assessed liabilities for subsequent               
          years (either an assessment resulting from a determined                     
          deficiency, or an assessment resulting from a mathematical error,           
          see sec. 6213(b)(1) and, (g)(2)(K)) and that, as a consequence,             
          some portion of the overpayment from those years is now available           
          as an offset against the deficiency for 1988 and 1990.  We are,             
          however, without jurisdiction in this proceeding to review                  
          respondent’s assessment of petitioner’s liabilities for years not           
          before the Court.  See sec. 6512(b)(1) (this Court has                      
          overpayment jurisdiction only for a year properly before the                
          Court); sec. 6214(b) (this Court shall consider facts with                  

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