William G. Wells - Page 2

                                                - 2 -                                                   
                                          FINDINGS OF FACT                                              
                  Some of the facts have been stipulated and are so found.                              
            The stipulation of facts and the attached exhibits are                                      
            incorporated herein by this reference.  At the time he filed the                            
            petition, petitioner resided in Santa Monica, California.                                   
                  Until August 1995, for a period of approximately 25 years,                            
            petitioner was employed as the president of Fujita Corp.                                    
                  In 1998, petitioner entered into an installment agreement                             
            with respondent as a method of paying his outstanding 1991 and                              
            1992 income tax liabilities (1998 installment agreement).                                   
            Pursuant to the 1998 installment agreement, instead of                                      
            petitioner’s receiving rental income payments from Miramar Hotel                            
            Corp. (Miramar), respondent was to receive monthly payments                                 
            directly from the Miramar.  Petitioner defaulted on the 1998                                
            installment agreement when Miramar ceased making payments to                                
            respondent.                                                                                 
                  On August 4, 1999, respondent issued to petitioner a Notice                           
            of Defaulted Installment Agreement Under IRC 6159(b), Notice of                             
            Intent to Levy Under IRC 6331(b) for 1991 and 1992 and a Final                              
            Notice of Intent to Levy and Notice of Your Right to a Hearing                              
            for 1991 and 1992.  As of this date, petitioner owed                                        
            $1,387,786.98 for 1991 and $865,486.80 for 1992--a total of                                 
            $2,253,273.78.                                                                              
                  On or about September 3, 1999, petitioner submitted to                                






Page:  Previous  1  2  3  4  5  6  7  8  Next

Last modified: May 25, 2011