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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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