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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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Last modified: May 25, 2011