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.
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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
Thornton, Judge:
Pursuant to section 6330(d), petitioners seek review of an Appeals Office determination sustaining a jeopardy levy.1
FINDINGS OF FACT
The parties have stipulated some facts, which we incorporate herein. When they filed their petition, petitioners resided in Kilauea, Hawaii.
Criminal Proceedings
On February 25, 1999, Mr. Zapara signed a plea agreement, pleading guilty to tax evasion and bank fraud. In the plea agreement, Mr. Zapara admitted that he evaded his taxes for tax years 1993, 1994, and 1995, and that he should have reported $465,943.62 in income he received as a result of…
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.
3Cited by23 opinions
- Greene-Thapedi v. Comm'rUnited States Tax Court · 2006
- Zapara v. Comm'rUnited States Tax Court · 2006
- Ian Michael Stead Belinda A. Stead v. United StatesCourt of Appeals for the Ninth Circuit · 2005
- Bussell v. Comm'rUnited States Tax Court · 2008
- McCall v. Comm'rUnited States Tax Court · 2009
18 more not listed; retrieve them via the Exa API.