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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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