Peter J. Bresson - Page 8

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          collect the taxes owed by Jaussaud Enterprises.  He attempted to            
          locate assets of Jaussaud Enterprises, but his efforts proved               
          unsuccessful.  At an undisclosed time, a representative of Jaussaud         
          Enterprises, presumably Willard D. Horwich (petitioner's counsel),          
          offered to satisfy the corporation's tax liability by way of a              
          "long-term" installment plan.  Revenue Officer Ryland rejected the          
          proposed arrangement because the period of limitations to collect           
          the delinquent taxes would have expired prior to full collection            
          under the proposed plan.  Ultimately, in a Report of Investigation          
          of Transferee Liability dated September 21, 1994, Revenue Officer           
          Ryland recommended that the IRS seek to collect the delinquent              
          taxes from petitioner as a transferee.                                      
               No notice of deficiency was issued to Jaussaud Enterprises for         
          the tax year ended February 28, 1991,  but an assessment was made           
          against Jaussaud Enterprises for that year on February 28, 1996.            
          Respondent sent a notice of transferee liability to petitioner              
          dated August 2, 1996, determining that he was liable as a                   
          transferee of the Alhambra property for Jaussaud Enterprises' tax           
          year ended February 28, 1991.                                               
               In October 1996, the collection file was assigned to Revenue           
          Officer Donald Dinsmore.  He searched for assets which the IRS              
          could levy against.  He checked IRS internal sources for financial          
          and other information concerning Jaussaud Enterprises; he also              
          searched Department of Motor Vehicles and real property records.            





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