Magdalena Pacheco - Page 6




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         $48,826 and $54,467 and section 6662(a) accuracy-related                     
         penalties of $9,765 and $10,893.                                             
              Tax Court Proceeding                                                    
              On January 25, 1999, petitioner and Mr. Pacheco petitioned              
         the Court, docket No. 1474-99, seeking a redetermination of the              
         deficiencies and the section 6662(a) accuracy-related penalties              
         for 1995 and 1996 (prior proceeding).                                        
              The Court entered a stipulated decision in the prior                    
         proceeding on June 29, 2000, with respect to the deficiencies and            
         penalties for 1995 and 1996, and no appeal was filed.  The                   
         parties have stipulated that relief under section 6015 was not               
         raised as an issue at any time during the prior proceeding.                  
         Taxable Year 1997                                                            
              Petitioner and Mr. Pacheco filed jointly for 1997 a Form                
         1040 prepared by a paid preparer.  RA Lunny subsequently expanded            
         the scope of his audit to include 1997.  On March 16, 2000,                  
         petitioner and Mr. Pacheco consented to the assessment of an                 
         additional tax liability of $9,503 plus interest for 1997.  No               
         penalties were assessed.                                                     
         Collection Action                                                            
              On June 6, 2002, petitioner filed a petition for levy action            
         with the Court, docket No. 9654-02L, in response to a Notice of              
         Determination Concerning Collection Action(s) Under Section 6320             
         and/or 6330 dated May 10, 2002, for 1995, 1996, and 1997.                    







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