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also indicated that the amounts due for petitioners’ 1970 and
1972 tax years were $64,167.11 and $86,690.39, respectively.
On December 15, 1978, MMI’s counsel sent respondent a letter
which stated that MMI would make 200 weekly installment payments
of $1,500 to respondent in satisfaction of the levy served on MMI
(December 15, 1978, payment agreement). The December 15, 1978,
payment agreement was sent from MMI’s counsel, Bruce D. Forman,
Esq., to respondent’s Revenue Officer Charles J. Hillsdale and
stated the following:
I am writing to confirm my understanding of our
conversation of December 13 and to put it in writing
for purposes of specific explanation to my client.
Commencing Friday, December 19, 1978, and every
Friday thereafter, Metropolitan Metals will forward to
the Internal Revenue Service in self-addressed stamped
envelopes to be provided by the Internal Revenue
Service to me, payment in the amount of $1,500.00 for
your levy on an account due and payable from
Metropolitan Metals, Inc. to Joseph F. and Carol P.
Enos, the same having been served on Metropolitan
Metals August 15, 1978.
It has been agreed that the outstanding account
payable is in the amount of $300,000.00 and,
accordingly, at this rate of payment it would take 200
weeks to make all of the payments required. Mr.
Roberts, President of Metropolitan Metals, Inc., has
agreed to inform me if business profits permit increase
payments and, at that time I would contact you so that
we could increase the rate of payment to decrease the
time during which payment would be made.
I appreciate the fact that you are cooperating
with us so that this account can be paid in a manner
consistent with continuing business and at the same
time, allowing the government to collect the amount
due.
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