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withheld in the amount of $3,924.45. MBL has no record of
receiving from petitioner any communication disputing the
accuracy of the 1990 Form W-2 or assigning petitioner's wage
income. Petitioner is being sued by MBL for commission
chargebacks relating to petitioner's 1990 and 1991 wage income.
On May 29, 1986, Ben D. Razon (assignor) and the law firm of
Hampton, Paleveda, Murphy, Cody & Levy (assignee or firm)
executed an Agreement for Assignment of Partnership Interest
(agreement) in Med-Center, a Florida partnership, in
consideration of the firm's payment of $30,000. Petitioner
executed the agreement on behalf of the firm. Additionally,
petitioner wrote a check, dated June 2, 1986, from an account in
his name to Mr. Razon in the amount of $30,000. In the memo
section of the check was the notation "Partnership Interest". As
to the firm's purchase of the partnership interest in Med-Center,
no note was ever executed and no loan amortization schedule was
ever issued.
The preamble to the agreement stated that the firm "desires
to take an assignment of a partial interest in the partnership
share owned by BEN D. RAZON". Additionally, the agreement
provided in relevant part:
1. BEN D. RAZON * * * for and in consideration of the
payment of $30,000.00, receipt of which is hereby
acknowledged and the assuming by HAMPTON, PALEVEDA,
MURPHY, CODY & LEVY of its proportionate share of the
Partnership liabilities of the above referenced
Partnership * * * does hereby irrevocably assign,
transfer and set over to the Assignee a proportionate
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