- 3 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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