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to the taxpayer’s property is if the SEC has taken no
steps to perfect its judgment and the Internal Revenue
Service chooses to file a notice of federal tax lien.
On October 23, 2001, Riley received a payment from
petitioners in the amount of $1,000. Petitioners designated this
payment to be applied against their income tax liability for
2000, and Riley applied it against that liability.
On December 19, 2001, Riley received a $2,000 payment from
petitioners. This payment was applied to petitioners’ income tax
liability for 1999.
Petitioners obtained the SEC’s permission to sell their
61-foot Hatteras yacht for $550,000 in December 2001.
Petitioners used the proceeds of this sale to pay off the debt
that encumbered the yacht (which was listed on their individual
CIS as $410,000) and to pay for their living expenses. None of
the proceeds of this sale were used towards the payment of
petitioners’ income tax liabilities for 1999 or 2000.
On February 4, 2002, Riley received two separate payments of
$1,000 each from petitioners. Both payments were applied to
petitioners’ income tax liability for 1999.
On March 19, 2002, Riley received a $2,000 payment from
petitioners. This payment was applied to petitioners’ income tax
liability for 1999.
On or about April 4, 2002, Riley faxed a message to McKinnon
seeking an explanation of how the filing of a Federal tax lien
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Last modified: May 25, 2011