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years. Petitioners also sought $10 million in damages from
respondent.
On November 22 and 27, 1991, a deposition (deposition) was
given by petitioner Joseph F. Enos (Mr. Enos), relating to the
lawsuit petitioners filed in the U.S. District Court for the
District of Massachusetts, Civil Action No. 90-10178-WAG. During
the deposition, George Eliopoulos, Esq., of the U.S. Department
of Justice, Tax Division, represented the United States, and
David Shaughnessy, Esq., represented Mr. Enos.
During the deposition, Mr. Enos discussed certain events
surrounding the August 15, 1978, notice of levy that was issued
to MMI. Mr. Enos also discussed the nature of petitioners’
business relationship with MMI.
Mr. Enos indicated that petitioners’ business had sales in
the millions of dollars during the 1970s. Mr. Enos also stated
that MMI was petitioners’ largest purchaser of scrap metal,
accounting for over 50 percent of their business during the
period in issue. Mr. Enos stated that petitioners kept an
“Accounts Receivable Ledger” for their business (petitioners’
business ledger), which reflected, in part, certain transactions
with MMI, from August 1977 until February 1979.
A letter from James S. Newell, C.P.A., Mr. Enos’s
accountant, dated February 15, 1978, to Mr. Hillsdale states:
“Enclosed herewith please find the personal and business
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