Joseph F. and Caroline Enos - Page 8

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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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