Mohammed Ali Gazi and Estate of Raees Iftekhar Gazi, Deceased, Mohammed Ali Gazi, Personal Representative - Page 2




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                                     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.                                       





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