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respondent in writing to sell the stock and apply the proceeds to
their outstanding tax liabilities.2 We remanded the case to the
Appeals Office for the purpose of establishing the value of the
stock accounts as of 60 days after August 23, 2001.3
Background
We adopt the findings of facts in Zapara I. For convenience
and clarity, we repeat here the facts necessary to understand the
discussion that follows, and we supplement the facts as
appropriate.
On June 1, 2000, respondent made a jeopardy levy with
respect to certain nominee stock accounts held on petitioners’
behalf. Respondent’s collection division took the position that
these stock accounts had a value of approximately $1 million--
more than enough to pay off fully petitioners’ then-outstanding
1993-98 tax liabilities of about $500,000.
By letter dated June 21, 2000, petitioners requested a
section 6330 Appeals hearing with respect to the jeopardy levy.
During the pendency of their Appeals Office case, petitioners
became concerned about a possible decline in the value of their
levied-upon stock (the stock). Petitioners’ then-representative,
2 Unless otherwise indicated, all Rule references are to the
Tax Court Rules of Practice and Procedure; all section references
are to the Internal Revenue Code in effect for the years in
issue.
3 After receiving respondent’s motion for reconsideration,
we stayed our Order remanding this case to the Appeals Office.
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