Michael A. Zapara and Gina A. Zapara - Page 3

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              THORNTON, Judge:  Pursuant to section 6330(d), petitioners              
         seek review of an Appeals Office determination sustaining a                  
         jeopardy levy.1                                                              
                                  FINDINGS OF FACT                                    
              The parties have stipulated some facts, which we incorporate            
         herein.  When they filed their petition, petitioners resided in              
         Kilauea, Hawaii.                                                             
         Criminal Proceedings                                                         
              On February 25, 1999, Mr. Zapara signed a plea agreement,               
         pleading guilty to tax evasion and bank fraud.  In the plea                  
         agreement, Mr. Zapara admitted that he evaded his taxes for tax              
         years 1993, 1994, and 1995, and that he should have reported                 
         $465,943.62 in income he received as a result of bank fraud and              
         other fraudulent schemes.  Also, on February 25, 1999, Mrs.                  
         Zapara signed a plea agreement, pleading guilty to subscribing to            
         a false tax return and admitting that she signed a tax return                
         that omitted income derived from the fraudulent activities of Mr.            
         Zapara.  Attorney Nicholas G. Spirtos (Mr. Spirtos) represented              
         petitioners during their criminal prosecutions and in negotiating            
         the plea agreements.  On February 26, 2001, a Federal District               
         Court sentenced Mr. Zapara.  James D. Henderson (Mr. Henderson)              
         represented Mr. Zapara in the sentencing phase of his criminal               
         case.                                                                        

               1 Unless otherwise indicated, all section references are to            
          the Internal Revenue Code, as amended.                                      




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