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

126 T.C. No. 11

UNITED STATES TAX COURT MICHAEL A. ZAPARA AND GINA A. ZAPARA, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent* Docket No. 9480-02L. Filed April 25, 2006. 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’…