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petitioner or to Hickey. On October 31, 1994, petitioner stopped
by Cox’s office without prior notice, and petitioner completed in
part and signed under penalties of perjury a Form 433-A,
Collection Information Statement for Individuals, and a Form
433-B, Collection Information Statement for Businesses
(collectively, financial statements). Cox informed petitioner at
that meeting that all relevant information on the financial
statements had to be completed in full. The financial statements
did not indicate that petitioner owned a house or a vehicle.
Petitioner told Cox that petitioner did not own a vehicle, that
his wife owned one vehicle subject to a lien, and that his
daughter owned the house in which he lived although, he stated,
she was a law student and tended not to stay at the house.
Petitioner informed Cox that the house had previously been
transferred to petitioner’s mother when he divorced his ex-wife
and that his mother transferred the house to the daughter when
the mother died in 1989. Petitioner informed Cox that petitioner
and the daughter split the cost of improvements made to the
house.
On November 3, 1994, Cox researched the records of the
Department of Motor Vehicles and learned that Hickey was listed
as the owner of two unencumbered vehicles, a 1993 Jeep Wrangler
and a 1993 Jeep Cherokee, with a total assessed value of $42,200.
Cox also researched the pertinent real property records and
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