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paperwork.5 Petitioner gave the paperwork to James Merriam.
Buttress went to the Tiburon residence many times. Petitioner
never spoke to him about respondent’s sale of the Tiburon
residence; however, she knew that Ted Merriam had been
communicating with respondent about selling the Tiburon
residence, and she believed that Ted Merriam was representing her
regarding respondent’s sale of the house.
On July 19, 1996, petitioner wrote a letter to Buttress in
which she said that Ted Merriam had told petitioner and James
Merriam that their real estate agent was advertising the sale of
the house, the proceeds from which they could use to pay
delinquent taxes.
On February 25, 1997, Buttress visited the Tiburon residence
and gave petitioner some paperwork including a notice of seizure
and a minimum bid worksheet that listed petitioner as the
taxpayer with a liability of $1,800,451.32 and the Tiburon
residence as the subject property. James Merriam was not at home
at the time. Petitioner called Ted Merriam. Ted Merriam told
petitioner to fax the paperwork to him. Later that day,
petitioner faxed that paperwork to Ted Merriam with a transmittal
letter that included the following:
Mike Buttress was just here and gave me the
following minimum bid worksheet.
5 Petitioner testified that this was the first time that
she knew about her transferee liability.
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