Francisco and Angela Aguirre - Page 2




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               Francisco and Angela Aguirre, pro se.                                  
               David C. Holtz, for respondent.                                        


                                       OPINION                                        
               COLVIN, Judge:  This matter is before the Court on                     
          respondent’s motion for summary judgment.  For reasons stated               
          below, we will grant respondent’s motion.                                   
               All section references are to the Internal Revenue Code as             
          amended, and all Rule references are to the Tax Court Rules of              
          Practice and Procedure.                                                     
                                     Background                                       
               Petitioners are married and lived in Hacienda Heights,                 
          California, when they filed their petition.                                 
               Petitioners filed joint returns for 1992, 1993, and 1994.              
          Respondent examined petitioners’ 1992, 1993, and 1994 returns in            
          1995.  On July 13, 1995, petitioners signed a Form 4549, Income             
          Tax Examination Changes, in which they consented to the immediate           
          assessment and collection of tax for 1992, 1993, and 1994.  It              
          stated:                                                                     
               Consent to Assessment and Collection – I do not wish to                
               exercise my appeal rights with the Internal Revenue                    
               Service or to contest in United States Tax Court the                   
               findings in this report.  Therefore, I give my consent                 
               to the immediate assessment and collection of any                      
               increase in tax and penalties, and accept any decrease                 
               in tax and penalties shown above, plus any additional                  
               interest as provided by law.  I understand that this                   
               report is subject to acceptance by the District                        
               Director.                                                              




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