- 13 -
4/14 419 714 2,500 8/30
4/14 419 672 2,500 8/28
4/14 419 648 2,500 8/25
7/19 47 940 3,000 9/15
7/19 47 942 3,000 9/15
7/19 47 988 2,500 9/19
9/19 47 1022 2,500 9/21
6/29 37 780 2,000 9/5
6/24 37 824 2,500 9/7
6/29 37 842 2,500 9/8
6/29 37 844 2,500 9/8
6/29 37 902 2,500 9/13
1The check number on each check corresponds to an
inscription in petitioners’ business ledger, under the “detail”
section of that record.
Moreover, petitioners’ business ledger indicates that there
were a number of payments from MMI to petitioners that were made
on or after August 15, 1978. Petitioners’ business ledger
indicates that petitioners credited MMI’s account with over
$800,000 after the August 15, 1978, notice of levy was served on
MMI, of which approximately $210,000 was purportedly paid to
petitioners on or after December 15, 1978. Along with the
numerous credits on MMI’s account, there appear to be numerous
debits on MMI’s account in petitioners’ business ledger
indicating that petitioners debited over $870,000 from MMI’s
account.
Respondent’s April 30, 1979, TDA entry states that
petitioners knew that as of April 30, 1979, MMI was no longer
making payments to respondent on the August 15, 1978, notice of
levy. Moreover, respondent’s April 30, 1979, TDA entry indicates
that respondent was also seeking to satisfy petitioners’ tax
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