- 3 - 1998, March 31, 1999, June 30, 1999, September 30, 1999, and December 31, 1999. Petitioner’s principal place of business was located in Philadelphia, Pennsylvania, when its petition in this case was filed. In September 2000, petitioner discovered that its employment taxes for the periods in issue had not been paid to the Internal Revenue Service (the Service) due to an embezzlement. Upon discovering the embezzlement, petitioner and/or its principal, Michael B. L. Hepps, entered into an agreement (installment agreement) with the Service to make periodic payments on the outstanding employment tax liability. The periodic payments were derived from, and depended upon, payments petitioner or petitioner’s principal received monthly from a third party, and the Service was aware of this fact.2 On some date after the installment agreement was implemented, the Service levied upon the third party, who allegedly owed money to petitioner or petitioner’s principal. Petitioner contends that the seizure was made in violation of an understanding it had with the Service. The seizure resulted in the third party, whose payments were funding the installment agreement, terminating its relationship with petitioner and/or petitioner’s principal. As a result, petitioner was no longer 2The record is unclear as to whether the third party was obligated to pay petitioner or petitioner’s principal.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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