Joseph F. and Caroline Enos - Page 13

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          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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