Zapara v. Comm'r
United States Tax Court
R moved for reconsideration of our Opinion reported in Zapara v. Commissioner, 124 T.C. 223 (2005) (Zapara I). Finding that R failed to comply with Ps' written request to liquidate Ps' levied-upon stock accounts as required by sec. 6335(f), I.R.C., Zapara I held that Ps were entitled to a credit for the value of their seized stock as of the date by which it should have been sold under the statute.
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R moved for reconsideration of our Opinion reported in Zapara v. Commissioner, 124 T.C. 223 (2005) (Zapara I). Finding that R failed to comply with Ps' written request to liquidate Ps' levied-upon stock accounts as required by sec. 6335(f), I.R.C., Zapara I held that Ps were entitled to a credit for the value of their seized stock as of the date by which it should have been sold under the statute. R contends that Ps' citation of sec. 6335(f), I.R.C., on reply brief constituted the untimely raising of a new issue and that the evidence does not show that Ps made sufficient written request…
1Opinion of the Court
SUPPLEMENTAL OPINION
Thornton, Judge:
Respondent has moved for reconsideration of our prior Opinion in Zapara v. Commissioner, 124 T.C. 223 (2005) (Zapara I). In Zapara I, we held, among other things, that in this action pursuant to section 6330(d) to review respondent’s jeopardy levy of certain stock accounts, petitioners are entitled to a credit for the value of their seized stock as of the date by which the stock should have been sold under section 6335(f); i.e., 60 days after petitioners requested respondent in writing to sell the stock and apply the proceeds to their outstanding tax…
2Cases cited30 opinions
- United States v. Whiting Pools, Inc.Supreme Court of the United States · 1983
- Bowen v. MassachusettsSupreme Court of the United States · 1988
- Sego v. CommissionerUnited States Tax Court · 2000
- United States v. National Bank of CommerceSupreme Court of the United States · 1985
- Lunsford v. Comm'rUnited States Tax Court · 2001
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