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record owner and manager of Heller's from 1985 to December,
1993."
Wrongful Levy Suit
In 1993, the Commissioner levied on stock brokerage
accounts at Paine Webber and Kidder Peabody which
petitioners owned jointly. Mrs. London challenged the levy
in a civil suit brought against the Commissioner in the
U.S. District Court of the District of Massachusetts. The
Government took Mr. London's deposition while the suit was
pending. In 1996, the parties to the suit agreed to a
settlement under which Mrs. London received $214,342 of
assets in the Paine Webber account and she was permitted to
keep her individual retirement account at Paine Webber,
amounting to $91,472.22, as of March 1996. Under the
settlement, Mrs. London also retained one-half of the
Kidder Peabody account or approximately $60,000.
Bank Accounts
During the years 1976 through 1985, petitioners either
individually, jointly, or with Mr. London's parents,
maintained the following bank accounts:
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