- 5 - insufficient income to generate a tax liability in 1990, and he did not have tax liabilities for 1997 and 1999 because he had sufficient overpayment credits from subsequent tax years to satisfy any outstanding tax liability. On June 1, 2005, petitioner mailed a Form 433-A to respondent’s Appeals Office, where his hearing request was being considered. On October 17, 2005, Settlement Officer Kathleen Derrick mailed petitioner a letter scheduling a telephonic hearing. The letter informed petitioner he could not contest the underlying income tax liability for 1990 because he had received a statutory notice of deficiency for that year and had not filed a petition in Tax Court. The letter also included literal transcripts for 1990 and 1997 through 2003 reflecting the balances due and the payments that were applied to those years.4 The letter indicated that if there were any “payments for which you believe you have not been credited, please provide copies of cancelled checks for these payments”. On November 3, 2005, a telephonic hearing was held between Ms. Derrick and petitioner, during which petitioner asserted he did not owe any of the income tax liabilities for the years at 4 The transcripts indicated overpayment credits of $300 and $678 were transferred from 2000 and 2001, respectively, and applied to petitioner’s 1989 tax liability. The transcripts also indicated overpayment credits of $1,309 and $677 were transferred from 2002 and 2003, respectively, and applied to petitioner’s 1990 tax liability.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 NextLast modified: November 10, 2007