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On January 10, 2001, Mr. Mahalaris spoke with Elizabeth
Lorsbach, an attorney at the law firm of Lotter and Bailin, P.C.
She advised him that petitioner was drunk when he submitted the
1989 return, that Mr. Chivers told petitioner that he had to file
a return for 1989 before Mr. Chivers could do anything to help
him, that petitioner did not receive $5 million, and that
petitioner was destitute.
On January 24, 2001, Mr. Mahalaris was advised by Mr.
Chivers that petitioner’s case was put in uncollectable status.
Mr. Chivers told Mr. Mahalaris that he (Mr. Chivers) did not
believe that the $5 million listed on the 1989 return was real in
the first place.
On April 17, 2001, Mr. Mahalaris filed four notices of
Federal tax lien identifying the three trusts and Pangia Asset
Management Corp. as petitioner’s nominees3 (nominee liens). The
nominee liens covered the income tax years 1986, 1987, 1988,
1989, and 1992.4 The total unpaid balance listed on the nominee
liens was $6,143,276.23, of which $4,341,486.84 was attributable
to 1989. That same day, respondent sent petitioner a notice
pursuant to section 6320 advising him of the filing of the
3 We use the term “nominee” throughout the opinion for
convenience only. We make no findings regarding whether the
three trusts or the corporation were nominees of petitioner.
4 One of the nominee liens mistakenly refers to 1996
instead of 1986.
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