124 T.C. No. 14
UNITED STATES TAX COURT
MICHAEL A. ZAPARA AND GINA A. ZAPARA, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 9480-02L. Filed May 17, 2005.
In a prior District Court criminal proceeding, Ps
pleaded guilty to various tax-related offenses with respect
to tax years 1993-95. Ps signed a Form 4549-CG, Income Tax
Examination Changes, in which they waived the right to
contest their tax liability in Tax Court and consented to
the immediate assessment and collection of their 1993-95
taxes. Subsequently, H’s plea agreement was found to
contain erroneous calculations as to the amount of the
Government’s tax loss; the District Court found that H had
received ineffective assistance of counsel in this regard
and reduced his sentence using the correct calculation.
In order to collect Ps’ 1993-95 tax liabilities as
shown on the Form 4549-CG, as well as Ps’ reported but
unpaid tax liabilities for tax years 1997 and 1998, R
made a jeopardy levy with respect to certain stock
accounts held on petitioners’ behalf. Ps requested an
Appeals Office hearing pursuant to sec. 6330(f), I.R.C.
During the Appeals Office case, Ps challenged their
underlying tax liabilities for 1993-95, alleging that
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