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$125,000.) To repay this debt, petitioner agreed to execute a note
providing for monthly installments of $798.32 each for 30 years,
with interest at 6.6 percent per annum.4 On August 1, 1993,
petitioner executed such a note. Beginning August 4, 1993, and
continuing through September 11, 1996, petitioner made the required
monthly payments to Jaussaud Enterprises. After September 1996,
petitioner made no further payments on the note.
Internal Revenue Service Actions
The Internal Revenue Service (IRS) sent several billing
notices to Jaussaud Enterprises. These notices mistakenly listed
the tax period involved as the year ended February 29, 1992. On
July 25, 1994, the IRS recorded in Los Angeles County a Notice of
Federal Tax Lien for Jaussaud Enterprises. The Notice of Federal
Tax Lien listed $117.73 as being owed for employment taxes for the
tax year ended December 31, 1993, and $79,207.53 as being owed for
corporation income taxes for the tax year ended February 28, 1992.5
William Ryland, an IRS revenue officer, was assigned to
4 The corporation adopted a resolution at the July 15,
1993, meeting which stated:
RESOLVED, that the corporation shall accept a
promissory note from Peter J. Bresson, payable $798.32
a month, the first payment to be made on August 1,
1993, and said note to continue for 30 years at an
interest rate of 6.6%.
5 The corporation made a payment of $1,603.76 on Aug. 24,
1993, and received a credit against its assessment.
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