- 30 - light of the large number of payments made by MMI to petitioners after the December 15, 1978, payment agreement between MMI and respondent, and, significantly, where many of those payments by MMI to petitioners, reflected on petitioners’ business ledger, do not appear to have been made by check or other negotiable instrument. We find petitioners’ contentions on brief that these payments represent “partial advance payments” to be incredible, especially in light of the following facts: After the December 15, 1978, payment agreement, respondent received less than $10,000 from MMI, while, at the same time, petitioners’ business ledger reflects that they received over $210,000; petitioners knew that MMI was having significant financial troubles; and petitioners participated in the negotiations between respondent and MMI. 12(...continued) your tax liability back then was around $310,000 as indicated in the levy? A. Right. Q. And they served a levy on Metals to collect that, all properties in their possession up to $310,000? A. Right. Q. Are you saying they paid you money after the levy was served which was attributable to money owed by Metals to you before the levy was served? A. Before the levy was served for amounts over and above the levy. Once the levy was served, that locked in the 310.Page: Previous 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 Next
Last modified: May 25, 2011