Freije v. Comm'r
United States Tax Court
P timely petitioned for review under sec. 6330(d), I.R.C., ofR's determination to proceed with levies to collect unpaidFederal income taxes for 1997, 1998, and 1999. P claimed in his Appeals hearing and herein that the proposedlevy for 1997 should not be sustained because a remittance hemade in 1997 with respect to his Federal income tax liabilityfor that year was instead applied improperly by R against a taxliability alleged by R to exist for 1995. Consequently, Pcontends,…
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P timely petitioned for review under sec. 6330(d), I.R.C., ofR's determination to proceed with levies to collect unpaidFederal income taxes for 1997, 1998, and 1999. P claimed in his Appeals hearing and herein that the proposedlevy for 1997 should not be sustained because a remittance hemade in 1997 with respect to his Federal income tax liabilityfor that year was instead applied improperly by R against a taxliability alleged by R to exist for 1995. Consequently, Pcontends, R is attempting to collect a tax that has been paid. Rcontends that this Court lacks jurisdiction to consider 1995,…
1Opinion of the Court
JOSEPH PAUL FREIJE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Freije v. Comm'r
No. 932-02L
United States Tax Court
125 T.C. 14; 2005 U.S. Tax Ct. LEXIS 23; 125 T.C. No. 3;
July 14, 2005, Filed
P timely petitioned for review under sec. 6330(d), I.R.C., of
R's determination to proceed with levies to collect unpaid
Federal income taxes for 1997, 1998, and 1999.
P claimed in his Appeals hearing and herein that the proposed
levy for 1997 should not be sustained because a remittance he
made in 1997 with respect to his Federal income tax liability
for that year was instead applied improperly by…
2Cases cited13 opinions
- Goza v. CommissionerUnited States Tax Court · 2000
- Montgomery v. Comm'rUnited States Tax Court · 2004
- Magana v. Comm'rUnited States Tax Court · 2002
- Freije v. Comm'rUnited States Tax Court · 2005
- Landry v. CommissionerUnited States Tax Court · 2001
8 more not listed; retrieve them via the Exa API.