- 2 - Background The record establishes and/or the parties do not dispute the following. At the time the petition was filed, petitioner Mohammed Ali Gazi (Mr. Gazi) resided in Pikesville, Maryland. On January 30, 1998, respondent issued a notice of defi- ciency (notice) to Mr. Gazi and his wife, Raees Iftekhar Gazi (Ms. Gazi),1 with respect to their taxable years 1983 through 1989. (We shall refer to Mr. Gazi and Ms. Gazi collectively as the Gazis.) The Gazis filed a petition with the Court with respect to that notice and commenced the case at docket No. 7950- 98. (We shall refer to the case at docket No. 7950-98 as the Gazis’ Tax Court case.) At the time the Gazis filed the petition commencing the Gazis’ Tax Court case, Jay E. Kauffman (Mr. Kauffman) represented them. On June 30, 2003, the parties in the Gazis’ Tax Court case submitted to the Court a stipulated decision document (stipulated decision document in the Gazis’ Tax Court case) that Mr. Kauffman executed on behalf of the Gazis and that counsel for the Commis- sioner of Internal Revenue (Commissioner) executed on behalf of the Commissioner. On July 8, 2003, pursuant to the agreement of the parties as reflected in the stipulated decision document in the Gazis’ Tax 1Ms. Gazi died on July 23, 2003.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: March 27, 2008