Zapara v. Comm'r
United States Tax Court
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.
Read the full summary
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 calculations as to the amount of the Government's tax loss; the District Court found that H had received ineffective assistance of counsel in this regard and reduced his sentence using the…
1Opinion of the Court
MICHAEL A. ZAPARA AND GINA A. ZAPARA, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Zapara v. Comm'r
No. 9480-02L
United States Tax Court
124 T.C. 223; 2005 U.S. Tax Ct. LEXIS 15; 124 T.C. No. 14;
May 17, 2005, Filed
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…
2Cases cited22 opinions
- United States v. Whiting Pools, Inc.Supreme Court of the United States · 1983
- Sego v. CommissionerUnited States Tax Court · 2000
- United States v. National Bank of CommerceSupreme Court of the United States · 1985
- Murphy v. United StatesCourt of Appeals for the First Circuit · 1995
- Phelps v. United StatesSupreme Court of the United States · 1975
17 more not listed; retrieve them via the Exa API.