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The decisions to be entered are not reviewable by any other
court, and this opinion should not be cited as authority.
Respondent sent separately to petitioner Josef Lah (Mr. Lah)
and petitioner Marie Lah (Mrs. Lah) (collectively, petitioners) a
Notice of Determination Concerning Collection Action(s) Under
Section 6320 and/or 6330 (notice of determination).2 The issue
for decision is whether respondent may proceed with the proposed
collection activities relating to 1990, 1991, 1992, and 1993
(years in issue).
Background
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time they filed
the petitions, petitioners resided in Chardon, Ohio.
Petitioners filed a chapter 11 bankruptcy petition on
November 25, 1985. The case was subsequently converted to a
chapter 7 proceeding.
On March 5, 1986, respondent assessed a section 6672 trust
fund recovery penalty (TFRP) against each petitioner of more than
$40,000.3 The TFRP resulted from the failure to withhold and pay
over income and Federal Insurance Contribution Act taxes for
2 Petitioners’ cases were consolidated for purposes of
trial, briefing, and opinion.
3 Respondent assessed $43,652 against Mr. Lah and $45,485
against Mrs. Lah.
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