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THORNTON, Judge: Pursuant to section 6330(d), petitioners
seek review of an Appeals Office determination sustaining a
jeopardy levy.1
FINDINGS OF FACT
The parties have stipulated some facts, which we incorporate
herein. When they filed their petition, petitioners resided in
Kilauea, Hawaii.
Criminal Proceedings
On February 25, 1999, Mr. Zapara signed a plea agreement,
pleading guilty to tax evasion and bank fraud. In the plea
agreement, Mr. Zapara admitted that he evaded his taxes for tax
years 1993, 1994, and 1995, and that he should have reported
$465,943.62 in income he received as a result of bank fraud and
other fraudulent schemes. Also, on February 25, 1999, Mrs.
Zapara signed a plea agreement, pleading guilty to subscribing to
a false tax return and admitting that she signed a tax return
that omitted income derived from the fraudulent activities of Mr.
Zapara. Attorney Nicholas G. Spirtos (Mr. Spirtos) represented
petitioners during their criminal prosecutions and in negotiating
the plea agreements. On February 26, 2001, a Federal District
Court sentenced Mr. Zapara. James D. Henderson (Mr. Henderson)
represented Mr. Zapara in the sentencing phase of his criminal
case.
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code, as amended.
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