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distributed to the creditors of Barbara Drake and petitioner, and
that Advisor Gordon believed that the attorney of Barbara Drake
and petitioner had “used the Court to bypass the Federal tax
Lien.” The memorandum further stated:
According to the settlement sheets the debtor
received $161,094.73 from the three sales. Although
the Bankruptcy Court approved the sales under 11 USC
363 the IRS received nothing. Attorney Satran had
knowledge of the Internal Revenue Service Federal Tax
Liens due to the considerable litigation involved in
this case. In fact Attorney Satran filed a motion with
the Court to disburse the funds including [sic] the IRS
liens. It is a mockery to the integrity [of the]
Bankruptcy Court if an Attorney can use it to defeat a
Federal Tax Lien allowing a Debtor to walk away with
the proceeds. The Bankruptcy Code was used because 11
USC 363 was authorized by the Court.
I informed Attorney Campobasso that Attorney
Satran had previously been suspended by the Bankruptcy
Court. Chief, US Bankruptcy Court Judge Carol J Keener
suspended attorney Satran from 01/30/1996 through
11/29/1996. The action of Attorney Satran in a Chapter
11 case [involving] Paula Wyner, Carlton House of
Brockton, Inc. was the cause of the suspension. I
think the Court should be informed of the conduct of
Attorney Satran in this case.
On January 30, 2002, Mr. Burke attended a meeting with
Settlement Officer O’Shea, who did not inform petitioner of his
communications with Advisor Gordon. Mr. Burke provided a copy of
Form 433-A, Collection Information Statement for Wage Earners and
Self-Employed Individuals, and Form 433-B, Collection Information
Statement for Businesses. A Form 656, Offer-in-Compromise, had
been completed but was not submitted to Settlement Officer O’Shea
for consideration. Petitioner concedes that the parties
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