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liability with assets other than the MMI account receivable.
Respondent’s May 10, 1979, TDA entry indicates that petitioners
were going to sell several parcels of real estate to pay part of
their tax liability. Respondent’s July 10, 1979, TDA entry
indicates that petitioners’ account at Bay Bank was levied upon.
On June 13, 1994, respondent issued notices of levy to a
number of institutions in an effort to collect $730,729.67 in
total liabilities from petitioners, $327,772.29 for 1971 and
$402,957.38 for 1972. Of the $327,772.29 liability for 1971,
$35,705.42 was for unpaid tax liability and $292,066.87 was for
accrued interest and penalties. The levies were placed on
petitioners’ accounts at Bridgewater Credit Union, in
Bridgewater, Massachusetts; Prudential Ins. Co. of America in
Newark, New Jersey; Shawmut Bank. N.A. in Boston, Massachusetts;
Baybank South in Westwood, Massachusetts; John Hancock Mutual in
Boston, Massachusetts; Bristol County Savings Bank in Taunton,
Massachusetts; Kidder Peabody Premium Acct. Fund in New York, New
York; and Kidder Peabody & Co., Inc., in New York, New York.
Respondent collected $87 from Shawmut Bank.
On September 15, 1994, respondent issued petitioners a
notice of seizure of real estate located at 19 Dana Street in
Taunton, Massachusetts, for a liability of $703,918.30. Also on
September 15, 1994, respondent issued petitioners a notice of
seizure for five additional parcels of real estate located on
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