- 4 -
tax return. Mr. Levin signed his name and Ms. Levin's name to
the Form 2848. In August 1982, Anson and the IRS executed a
Form 872-A, extending indefinitely the period of limitations for
assessment of petitioners' taxes for 1980.
On September 17, 1985, the IRS sent to petitioners a
statutory notice of deficiency, determining deficiencies of
$41,609 for 1979 and $129,895 for 1980 in petitioners' Federal
income taxes. On December 5, 1985, a petition was filed in this
case by Hochman and Gelfand as attorneys of record. This case
was associated with numerous cases involving Schulman tax
shelters. On August 10, 1989, the decision was entered pursuant
to a stipulation bearing the original signature of Gelfand. The
stipulation also bore a machine copy of signatures appearing to
be those of petitioners. The decision determined that there was
no deficiency for 1979 and that there was a deficiency in
petitioners' Federal income tax for 1980 in the amount of
$129,895. The decision became final 90 days thereafter. Secs.
7481(a)(1), 7483.
On December 4, 1991, petitioners delivered an Offer in
Compromise to the IRS, seeking an agreement to reduce their
liability for 1980 income taxes. That offer was rejected on
February 16, 1992. On May 13, 1992, petitioners filed a petition
in bankruptcy. An order of discharge was dated September 11,
1992. On July 16, 1993, a Notice of Levy on Wages, Salary, and
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011