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 thatPage: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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