Law Offices of Michael B. L. Hepps - Page 3

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          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.                      





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