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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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