Taxpayers received a Notice of Deficiency from the IRS proposing additional income tax for alleged unreported taxable income from the sale of securities. DeWitt Law represented the Taxpayers and challenged the Notice of Deficiency by filing a Petition in U.S. Tax Court. DeWitt Law argued that the proposed assessment should be reversed because the Taxpayers did not own the securities at issue. After completing discovery, IRS counsel agreed to reverse the Notice of Deficiency. The Court entered an order reversing the proposed tax assessment to $0.