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petitioner could seek assistance with regard to the 2004 tax year
from the “TAO’s Office”.2
On March 16, 2006, petitioner filed a petition for lien or
levy action and for redetermination of a deficiency with this
Court. Because respondent applied petitioner’s tax refund from
the year 2005 to his outstanding tax liabilities from 2004 as
well as from 1999, according to respondent petitioner no longer
has an unpaid tax liability for the year 2004 and owes
approximately $282.03 for the 1999 tax year.
Petitioner contends that respondent abused his discretion in
refusing to enter into a settlement agreement with him unless the
agreement included the 2004 tax year as well as the 1999 tax
year. Further, petitioner contends that he was owed a refund for
the tax year 2004, rather than owing additional tax as respondent
determined. This claim, according to petitioner, was never
properly evaluated by respondent’s Appeals officer.
Consequently, petitioner contends that respondent acted
improperly in applying a refund due petitioner for the tax year
2005 to 2004, for which year, claims petitioner, he did not owe
any tax. Had respondent applied the 2005 refund entirely to
amounts owed for 1999, claims petitioner, the liability for 1999
would have been completely paid.
2We assume that this refers to the Taxpayer Assistance
Office.
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Last modified: November 10, 2007