- 9 -
1997, 1998, and 1999. On February 18, 2001, respondent received
a Form 12153, Request for a Collection Due Process Hearing, from
petitioner (but not Mrs. Freije) regarding respondent's proposed
collection action for the foregoing years. As grounds for
disagreeing with the proposed collection action, petitioner wrote
as follows, "I am scheduled for audit in Greenwood IN. You
people have falsely accused me of writing a bad check for
$10,000.00. You deny receiving over $13,000.00 in estimated
taxes. * * * I have amended 1997, 1998, 1999. You owe me over
$24,000.00."
On February 27, 2001, the Freijes filed an amended Federal
income tax return for 1997, claiming an increase in itemized
deductions of $14,9408 and a resulting refund of $6,395. On
March 27, 2001, the Freijes filed amended Federal income tax
returns for 1998 and 1999, claiming a $14,9409 reduction in
previously reported adjusted gross income for each of those years
and resulting refunds of $8,996.50 and $8,752.73, respectively.10
8 This figure equaled the portion of an increase in the
Freijes' income for 1999 that had been proposed in an examination
of the 1999 return, with which petitioner disagreed.
9 These figures were likewise designed to offset the same
proposed examination increase in the Freijes' income for 1999
with which petitioner disagreed. See supra note 8.
10 The 1998 and 1999 amended returns both claimed amounts
for estimated tax payments that were different from the amounts
claimed in the original returns for those years.
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