Nelson I. and Esther S. Goodman - Page 2

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          Concerning Collection Action(s) Under Section 6320 and/or 6330              
          that respondent sent to petitioners.  At the time the petition              
          was filed, petitioners resided in Lawrence, New York.                       
                                     Background                                       
          Origin of the Tax Liability                                                 
               Petitioners timely filed their Federal income tax return for           
          1995 without remittance.  The tax shown on the return was                   
          assessed, and notice and demand was issued.  The tax was paid on            
          October 16, 1997.                                                           
               The return was subsequently examined, and a deficiency in              
          income tax was proposed.  One of the issues in the examination              
          was the treatment of certain stock as section 1244 stock.  Martin           
          D. Tropper (Mr. Tropper), pursuant to a power of attorney, was              
          petitioners’ representative in the administrative proceedings.              
          Mr. Tropper was not, at the time, admitted to practice before the           
          United States Tax Court.                                                    
               Petitioners could not reach an agreement with the                      
          Commissioner on the proposed deficiency, and a statutory notice             
          of deficiency was issued.  Petitioners filed pro sese a petition            
          with the Tax Court at docket No. 1262-01S for redetermination of            
          the deficiency for 1995.  Petitioners signed on February 10,                
          2002, a stipulated decision document in which they agreed:  (1)             
          To a deficiency of $26,955.75, (2) that they had no liability for           
          the section 6662 accuracy-related penalty, and (3) that “interest           






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