Josef and Marie Lah - Page 3

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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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