- 2 - 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Ps were precluded from challenging their underlying 1993- 95 tax liabilities and that the jeopardy levy would not be withdrawn.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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011