William F. Urbano and Flota L. Urbano - Page 1

                                   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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