- 8 - 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 businessPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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