Dori R. Merriam, Transferee - Page 10

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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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