Michael A. Zapara and Gina A. Zapara - Page 6

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              Taxable                                                                 
              Period         Tax        Penalty        Interest                       
              1993       $122,463      $91,847        $157,408                        
              1994          3,695        2,771           4,221                        
         1995         17,312       12,984          15,085                             
         1997         42,049        4,245           7,453                             
              1998         38,264        2,167           4,060                        
              On June 1, 2000, respondent issued Forms 668-A(c)(DO),                  
         Notice of Levy, to Travis Morgan Securities, Inc., with respect              
         to certain nominee stock accounts held on petitioners’ behalf.               
         Respondent’s collection division took the position that these                
         stock accounts had a value of approximately $1 million--more than            
         enough to pay off fully petitioners’ then-outstanding tax                    
         liabilities of about $500,000.                                               
              By letter dated June 21, 2000, petitioners requested a                  
         section 6330 Appeals hearing with respect to the jeopardy levy.              
         In November 2000, Appeals Officer Janice Rich was assigned to                
         consider petitioners’ request for an Appeals hearing.  In the                
         initial stages of the proceedings in the Appeals Office,                     
         petitioners were represented by Mr. Spirtos; however, on                     
         April 30, 2001, respondent received a Form 2848, Power of                    
         Attorney and Declaration of Representative, for Steven R. Mather             
         (Mr. Mather).  From that point on, Mr. Mather represented                    
         petitioners in the Appeals Office.                                           
              In their Appeals Office case, petitioners raised the                    
         following issues:  (1) That they were not liable for the amounts             
         of tax asserted in the Form 4549-CG because they signed that form            





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