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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
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