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Ciraolo) entered an appearance in the Gazis’ Tax Court case. In
the motion for leave to file a motion to vacate final decision in
the Gazis’ Tax Court case, Mr. Gazi argued that the Gazis’ Tax
Court decision resulted from the perpetration of fraud on the
Court by Mr. Kauffman and counsel for the Commissioner. Accord-
ing to Mr. Gazi, the stipulated decision document in the Gazis’
Tax Court case was executed without the Gazis’ knowledge or
authorization. On December 15, 2004, the Court granted the
motion to withdraw Mr. Kauffman as counsel in the Gazis’ Tax
Court case.
On May 23, 2005, a revenue officer with respondent’s collec-
tion division (revenue officer) contacted Ms. Ciraolo, the
authorized representative of Mr. Gazi and Ms. Gazi’s estate, and
advised her that he was recommending that a notice of Federal tax
lien be filed with respect to the Gazis’ unpaid liabilities for
1983 through 1989. In response, Ms. Ciraolo requested a hearing
under respondent’s Collection Appeals Program (CAP).
On June 14, 2005, a settlement officer (CAP hearing settle-
ment officer) held a CAP hearing with Ms. Ciraolo. The CAP
4(...continued)
case and to amend the caption of that case was filed with the
Court. Thereafter, the Court issued an Order granting that
motion and, inter alia, changing the caption of the Gazis’ Tax
Court case to read “Mohammed A. Gazi and Estate of Raees I. Gazi,
Deceased, Mohammed A. Gazi, Personal Representative, Petitioners
v. Commissioner of Internal Revenue, Respondent”. (We shall
refer to the estate of Raees Iftekhar Gazi, deceased, Mohammed A.
Gazi, personal representative, as Ms. Gazi’s estate.)
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