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Mr. Enos knew MMI had agreed to make payments to respondent
for the satisfaction of petitioners’ tax liability to respondent.
Mr. Enos believed that the account receivable had a value
different from the $300,000 that was agreed to in the December
15, 1978, payment agreement.
Petitioners received money from MMI after the August 15,
1978, notice of levy was issued to MMI for the part of the
account receivable that exceeded the amount of the August 15,
1978, notice of levy.
In respondent’s record of petitioners’ account, a Form 2-27,
TDA3 (Taxpayer Delinquent Account) History Record form for the
period from January 1, 1978, to July 2, 1981, the October 23,
1978, entry states that petitioners’ counsel advised respondent
that petitioners were meeting with representatives of MMI in
Harrisburg, Pennsylvania, to resolve the amount owed by MMI to
petitioners. Respondent’s October 31, 1978, TDA entry states
that petitioners informed respondent that petitioners and MMI did
not agree as to the amount of MMI’s liability to petitioners.
That entry also states that MMI provided petitioners with their
records so that MMI and petitioners could agree on a figure for
the account receivable. Respondent’s November 3, 1978, TDA entry
states that MMI’s attorney, Mr. Forman, was contacted by
3Coggin v. Commissioner, T.C. Memo. 1993-209, affd. 71 F.3d
855 (11th Cir. 1996), describes the function of TDAs.
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