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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.
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Last modified: November 10, 2007