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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be withdrawn.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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