- 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’ taxPage: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
Last modified: May 25, 2011