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ZAPARA v. COMMISSIONER

Docket No. 9480-02L.

124 T.C. 223 (2005)

124 T.C. No. 14

MICHAEL A. ZAPARA AND GINA A. ZAPARA, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 17, 2005.

Attorney(s) appearing for the Case

Michael A. Zapara and Gina A. Zapara, pro sese.

Lorraine Y. Wu, for respondent.

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...

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