Michael A. Zapara and Gina A. Zapara v. Commissioner

124 T.C. No. 14

UNITED STATES TAX COURT MICHAEL A. ZAPARA AND GINA A. ZAPARA, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9480-02L. Filed May 17, 2005. In a prior District Court criminal proceeding, Ps pleaded guilty to various tax-related offenses with respect to tax years 1993-95. Ps signed a Form 4549-CG, Income Tax Examination Changes, in which they waived the right to contest their tax liability in Tax Court and consented to the immediate assessment and collection of their 1993-95 taxes. Subsequently, H’s plea agreement was found to contain erroneous…