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UNITED STATES v. COMPARATO

July 2, 1993

UNITED STATES OF AMERICA, Plaintiff,
v.
ANTHONY COMPARATO, individually and as Administrator of the Estate of JOHN COMPARATO; MILDRED COMPARATO; MILLICENT COMPARATO; DIANA COMPARATO CARLUCCI; BARON & VESEL, P.C.; and JAMES COLLINS, Clerk of the Surrogate's Court of New York, Queens County, Defendants.



The opinion of the court was delivered by: REENA RAGGI

 RAGGI, District Judge:

 Factual Background

 1. The Comparatos' Tax Liabilities

 The long history of civil and criminal tax disputes between the Comparatos and the United States is detailed in a recent Tax Court opinion, Comparato v. Commissioner of Internal Revenue, 65 T.C.M. (CCH) 1890 (T.C. 1993), familiarity with which is assumed. Because that decision resolves all outstanding disputes between the parties as to the Comparatos' tax liabilities, this court simply notes the following now-undisputed jeopardy assessments filed against the Comparatos by the Internal Revenue Service. *fn1"

 With respect to Anthony Comparato:

 (1) On September 30, 1985, he was assessed $ 10,253.75 in tax, interest, and penalties for tax year 1983.

 (2) On May 19, 1986, he was assessed $ 1,108.12 in tax, interest, and penalties for tax year 1984.

 (3) On July 7, 1986, he was assessed $ 365,048.19 in tax, interest, and penalties for tax year 1985.

 (4) On October 27, 1986, he was assessed $ 14,832.74 in tax, interest, and penalties for tax year 1982.

 (5) On August 23, 1989, he was assessed a total of $ 153,565.00 representing $ 32,379.00 in tax, interest, and penalties for tax year 1974, $ 72,197.00 for tax year 1975, and $ 48,989.00 for tax year 1976.

 (6) On August 23, 1989, he was further assessed $ 131,727.19, representing $ 1,044.00 in tax, interest, and penalties for tax year 1981, an additional $ 23,791.75 for tax year 1982, an additional $ 20,327.50 for tax year 1983, and an additional $ 86,563.94 for tax year 1984.

 These assessments total $ 676,534.99.

 With respect to Mildred Comparato:

 (1) On August 23, 1989, she was assessed $ 118,841.00, representing $ 20,447.00 in tax, interest, and penalties for tax year 1974, $ 58,416.00 for tax year 1975, and $ 39,978.00 for tax year 1976.

 (2) On August 23, 1989, she was further assessed $ 96,674.22, representing $ 1,044.00 in tax, interest, and penalties for tax year 1981, $ 4,324.50 for tax year 1982, $ 3,966.00 for tax year 1983, and $ 87,339.72 for tax year 1984.

 These assessments total $ 215,515.22.

 2. Malpractice Actions Relating to the Treatment and Death of ...


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