(b) Credits against estimated tax.---The commissioner may prescribe regulations providing for the crediting against the estimated tax under article nine-a for any taxable year of the amount determined to be an overpayment of tax under such article for a preceding taxable year. If any overpayment of tax is so claimed as a credit against estimated tax for the succeeding taxable year, such amount shall be considered as a payment of the tax under article nine-a of this chapter for the succeeding taxable year (whether or not claimed as a credit in the declaration of estimated tax for such succeeding taxable year), and no claim for credit or refund of such overpayment shall be allowed for the taxable year for which the overpayment arises, except upon request to the commissioner on or before the last day prescribed for the filing of the return for the succeeding taxable year, determined with regard to any extension of time granted. If good cause is shown for reversing the credit, the commissioner may, in his or her discretion, credit the overpayment against a liability or refund the overpayment without interest. Provided, the person who made the overpayment will not be relieved of liability for any penalty imposed for a consequent underpayment of estimated tax for the succeeding taxable year. The decision of the commissioner to grant or deny the request is final and not subject to further administrative or judicial review.

(c) Rule where no tax liability.---If there is no tax liability for a period in respect of which an amount is paid as tax, such amount shall be considered an overpayment.

(d) Assessment and collection after limitation period.---If any amount of tax is assessed or collected after the expiration of the period of limitations properly applicable thereto, such amount shall be considered an overpayment.

(e) Assignment of overpayment.---A credit for an overpayment of tax under article nine, nine-a, nine-b or nine-c may be assigned by the taxpayer to a corporation liable to pay taxes under any of such articles, and the assignee of the whole or any part of such credit, on filing such assignment with the tax commission, shall thereupon be entitled to credit upon the books of the tax commission for the amount thereof on its current account for taxes, in the same manner and to the same effect as though the credit had originally been allowed in its favor.