Mitchell F. Skrizowski - Page 6

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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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