122 T.C. No. 22
UNITED STATES TAX COURT
WILLIAM F. URBANO AND FLOTA L. URBANO, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 14466-02L. Filed June 10, 2004.
Following R’s audit of Ps’ 1993 through 1996
Federal income tax returns, R’s revenue agent (A)
prepared a Form 4549-CG, Income Tax Examination
Changes, that listed $7,556.09 as the total amount of
Federal income taxes, penalties, and interest Ps owed
for those years. Ps signed the form, consenting to R’s
immediate assessment and collection of the $7,556.09
and waiving their right to challenge in this Court the
findings of A contained in that form, and delivered the
signed form to A with a check for the stated amount.
Subsequently, R determined that A had understated the
interest due for 1993 by prematurely taking into
account net operating loss (NOL) carrybacks to that
year in disregard of sec. 6601(d)(1), I.R.C.
R determined that Ps were liable for recalculated
interest of $39,558.63 for 1993, instead of $1,548.23
as originally calculated by A, and filed a notice of
Federal tax lien to secure Ps’ payment of $31,455.49 of
that interest considered by R still to be owed for 1993
as of the time of the lien’s filing. At the hearing
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