Joseph F. and Caroline Enos - Page 7

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               On June 24, 1981, the U.S. Bankruptcy Court for the Middle             
          District of Pennsylvania issued an order of adjudication,                   
          ordering MMI’s case to proceed under the provisions of the                  
          Bankruptcy Act, appointing Mr. DeHart to the position of trustee            
          for MMI (bankruptcy trustee), and setting the amount of the bond            
          of the bankruptcy trustee at $100,000.                                      
               On May 12, 1982, respondent filed a second amended proof of            
          claim for internal revenue taxes, claim 173 (1982 proof of claim)           
          in the U.S. Bankruptcy Court for the Middle District of                     
          Pennsylvania.  Respondent’s 1982 proof of claim stated that                 
          respondent had a priority claim under section 64a(5) based on the           
          August 15, 1978, notice of levy and the December 15, 1978,                  
          payment agreement.  The 1982 proof of claim also stated that                
          interest would accrue on the $248,710.95 due under the 1982 proof           
          of claim from MMI at a rate of $72.77 per day.                              
               On April 5, 1989, respondent filed another amended proof of            
          claim with the U.S. Bankruptcy Court for the Middle District of             
          Pennsylvania, claim 175, claiming an amount due from MMI in the             
          amount of $149,321.40.                                                      
               On January 24, 1990, petitioners filed a complaint against             
          respondent in the U.S. District Court for the District of                   
          Massachusetts, Civil Action No. 90-10178-WAG.  Petitioners sought           
          to have respondent remove certain tax liens on their property,              
          relating to the tax liabilities from their 1971 and 1972 tax                






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