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Income Tax Examination and Form 4549-CG
On February 29, 2000, petitioners signed a Form 4549-CG,
Income Tax Examination Changes, for taxable years 1993, 1994, and
1995. The unreported income adjustments on the Form 4549-CG
total $361,559 for 1993, $23,894 for 1994, and $80,489 for 1995.2
The Form 4549-CG shows balances due, exclusive of interest and
penalties, of $122,463 for 1993, $3,695 for 1994, and $17,312 for
1995. After adding section 6663 fraud penalties and interest,
the Form 4549-CG shows balances due of $344,498 for 1993, $9,560
for 1994, and $40,657 for 1995.
Petitioners’ 1997 and 1998 Income Tax Liabilities
On May 15, 2000, petitioners filed their 1997 and 1998
income tax returns showing taxes due. On May 15, 2000, on the
basis of those returns, respondent made assessments of $30,744.60
for 1997 and $31,529.80 for 1998, as well as interest, penalties,
and additions to tax.
Jeopardy Levy
On June 1, 2000, respondent provided petitioners with
“Notice of Jeopardy Levy and Right of Appeal” for the following
unpaid tax amounts:
2 The adjustments for 1993 include (in addition to the
$361,559 unreported income adjustments) a $14,100 adjustment for
exemptions.
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