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necessary, the Appeals officer determined that the proposed levy
could proceed.
On January 14, 2002, petitioner filed a timely petition with
this Court for review of the determination. The petition assigns
a litany of errors to the determination, including (i) that
respondent changed petitioner's 1995 through 1999 returns without
notifying him; (ii) that respondent altered a check petitioner
submitted in connection with the erroneous posting of his $1,776
payment as $11,776 for 1997; and (iii) that respondent denied
receipt of certain payments petitioner made. Petitioner seeks as
a remedy a refund of all Federal income taxes he paid for taxable
years 1995 through 2001.
After the petition was filed, on March 11, 2002, respondent
issued a notice of deficiency to the Freijes with respect to
their 1999 taxable year. In the notice of deficiency, respondent
determined, inter alia, that the Freijes were not entitled to the
$320 casualty loss claimed in the 1999 return but were entitled
to miscellaneous deductions of $8,935 (subject to the 2-percent
limitation of section 67(a)). On the same day that the notice of
deficiency was issued, respondent issued a claim disallowance
letter to the Freijes, denying their claims for refund in their
amended returns filed for 1997, 1998, and 1999. No petition was
filed in this Court with respect to the notice of deficiency for
1999.
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