Joseph Paul Freije - Page 12

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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             

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