Michael A. Zapara and Gina A. Zapara - Page 2

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               they had signed the Form 4549-CG under duress or                       
               coercion and that the Form 4549-CG overstated their                    
               true tax liability.  Pursuant to sec. 6335(f), I.R.C.,                 
               Ps also requested R to sell the stock in the seized                    
               stock accounts and apply the proceeds to their                         
               outstanding tax liabilities.                                           
                    R neither sold the stock in the seized accounts                   
               nor made a determination that selling the stock would                  
               not be in the best interests of the United States.  R                  
               sent Ps a notice of determination concluding that Ps                   
               were precluded from challenging their underlying 1993-                 
               95 tax liabilities and that the jeopardy levy would not                
               be withdrawn.  Ps petitioned this Court to review R’s                  
               determination.  Ps claim that the value of the seized                  
               stock accounts has declined significantly since they                   
               requested R to liquidate them.                                         
                                                                                     
                    1.  Held, Ps have not shown that they signed the                  
               Form 4549-CG under duress or coercion, or that it                      
               includes erroneous loss calculations; Ps may not                       
               contest their underlying tax liabilities for 1993-95.                  
                   2.  Held, further, R has complied with the notice                  
              requirements of sec. 6331(a) and (d), I.R.C.                            
                   3.  Held, further, Ps are entitled to a credit for                 
              the value of the seized stock accounts as of the date                   
              by which the stock should have been sold under sec.                     
              6335(f), I.R.C.; i.e., 60 days from the date Ps                         
              requested R to sell the stock and apply the proceeds to                 
              their outstanding tax liabilities.                                      

              Michael A. Zapara and Gina A. Zapara, pro sese.                         
              Lorraine Y. Wu, for respondent.                                         














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