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Court challenging the notice of deficiency. On September 26,
1997, pursuant to an agreement between the parties, we entered a
decision holding that petitioners were liable for a penalty in
the amount of $13,858 pursuant to section 6662(a) for 1989 and
that petitioners owed an unpaid prior assessment of $69,289 for
1989. See Summers v. Commissioner, docket No. 17005-95. On
November 24, 1997, respondent assessed petitioners the section
6662(a) penalty in the amount of $13,858 for petitioners’ 1989
taxable year.
Litigation Involving Petitioners and Commonwealth Land Title
Insurance Company
During July 1997, respondent filed a Notice of Federal Tax
Lien (NFTL) against petitioners in Berks and Montgomery Counties,
Pennsylvania, relating to petitioners’ unpaid tax liabilities for
1982 through 1990. Petitioners’ surname, however, was misspelled
as “Hugh D. & Teresa E. Summer” on the NFTL filed in Montgomery
County, Pennsylvania.
On July 31, 1997, Mr. Summers sold two properties to
Leemilt’s Petroleum, Inc.: (1) 270 W. Greenwich Street, Reading,
Berks County, Pennsylvania (the Berks County Property); and (2)
Buckert Road and Keim Street, Lower Pottsgrove Township,
Montgomery County, Pennsylvania (the Montgomery County Property).
Commonwealth Land Title Insurance Company (Commonwealth) insured
the title on both properties for the purchaser, Leemilt’s
Petroleum, Inc., and settlement on both properties was on
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