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H. Post-Trial Issues
1. Tort Claims for Alleged Violations of Federal Acts
Petitioner asserted tort claims for alleged violations by
former and current IRS officials of the Privacy Act of 1974, 5
U.S.C. sec. 552a (1994), and other purported Federal statutes for
which he provided no citations. This Court has only such
jurisdiction as provided by Congress. See sec. 7442; see also
Estate of Meyer v. Commissioner, 84 T.C. 560, 562 (1985); Adams
v. Commissioner, 72 T.C. 81, 84 (1979), affd. without published
opinion 688 F.2d 815 (2d Cir. 1982). Because petitioner has not
established that we have jurisdiction to review these claims, we
do not consider this issue.
2. Amendment of Petition To Raise Post-Trial Issues
Petitioner sought to amend his petition to claim the
deductibility of mortgage interest for the Creek Drive house for
1994 and 1995 and an unspecified amount of medical expenses for
1995.
Leave to amend a petition is freely granted when justice
requires. See Rule 41(a). However, where no justification for
delay exists or if the adverse party would be unfairly prejudiced
or substantially inconvenienced by the granting of leave to
amend, the request is denied. See Evans v. Syracuse City Sch.
Dist., 704 F.2d 44, 46-47 (2d Cir. 1983); Shea v. Commissioner,
T.C. Memo. 1991-518; Kloppenberg & Co. v. Commissioner, T.C.
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