Angelo F. DeJoy - Page 3

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          petitioner’s corporations were engaged.  Car Audio apparently               
          operated until 1988 when it ceased operations.  Car Stereo                  
          apparently went into involuntary bankruptcy in 1989, and                    
          apparently by 1989, Audio Distributors had gone out of business.            
               In August of 1990, petitioner sold a parcel of real estate             
          that he owned personally located in Bayshore, New York, and                 
          petitioner used $8,275 of the sales proceeds to pay to the State            
          of New York an outstanding sales tax liability of Car Stereo.               
          The State of New York had previously obtained a judgment against            
          petitioner personally with regard to the outstanding sales tax              
          liability of Car Stereo and had filed a judgment lien against the           
          above real property.  Upon petitioner’s payment of the $8,275 to            
          New York State, the lien on the property was released, and                  
          petitioner’s personal liability to the State with respect to the            
          outstanding New York State sales tax liability of Car Stereo was            
          paid off.                                                                   
               In early 1991, petitioner paid the State of New York a total           
          of $23,730 in outstanding sales tax liabilities of Car Stereo and           
          of Car Audio.                                                               
               Also in 1991, petitioner paid the United States a total of             
          approximately $23,662 in section 6672 responsible officer                   
          penalties that had been assessed by respondent against petitioner           
          relating to unpaid trust fund Federal employment taxes owed by              
          petitioner’s S corporations.                                                

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