Michael A. Zapara and Gina A. Zapara - Page 1

                                   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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