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Court case, the Court entered a decision (Gazis’ Tax Court
decision) in the Gazis’ Tax Court case. That decision ordered
and decided that for the Gazis’ taxable years 1983 through 1989
the Gazis are liable for deficiencies in their Federal income tax
(tax) totaling $219,723 and certain additions to tax totaling
$376,041.33.
On November 10, 2003, respondent assessed tax, as well as
additions to tax and interest as provided by law, for each of the
Gazis’ taxable years 1983 through 1989. (We shall refer to those
unpaid assessed amounts, as well as interest as provided by law
accrued after November 10, 2003, as the Gazis’ unpaid liabilities
for 1983 through 1989.)
On November 10, 2003, respondent issued to Mr. Gazi2 the
notice and demand for payment required by section 6303(a)3 with
respect to the Gazis’ unpaid liabilities for 1983 through 1989.
On March 12, 2004, Mr. Gazi filed with the Court a motion
for leave to file a motion to vacate final decision in the Gazis’
Tax Court case and a motion to withdraw Mr. Kauffman as counsel
in that case.4 On the same date, Caroline D. Ciraolo (Ms.
2See supra note 1.
3All section references are to the Internal Revenue Code in
effect at all relevant times. All Rule references are to the Tax
Court Rules of Practice and Procedure.
4Also on Mar. 12, 2004, a motion under Rule 63(a) to
substitute the proper party for Ms. Gazi in the Gazis’ Tax Court
(continued...)
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