- 18 - A I don't recollect seeing one. I recollect that they said you have a liability on it--a big liability on it. Q Okay. A And that is when I think everybody got back together and they got talking to each other up at Williams, Cox and Weidner and whatever in the heck their name is. Q When they told you there was a return with a lot of tax due, did that--that got everybody nervous and talking. True? A Well, I think it got--you know, when we raised hell with them and said, Wait a minute now, here. You were in here from ground floor and all the rest of that and everything. They went back and got talking amongst themselves, I think. After Briggs "raised hell" with WCWC, Turner sent to Williams, his manager, a fax that stated in part: I believe you will agree that we gave them sound advice in October, 1988. If they did not follow through with the advice, they have a problem, because we did explain the options to them. Let me hear from you. ACT would not have had a substantial tax liability from the JSL sale if it had liquidated in accordance with section 337. WCWC's failure to inform the ACT shareholders about the timing requirement of section 337, along with Briggs' anger at WCWC because of the ACT tax liability and Turner's attempt to protect WCWC's interests in the memorandum to Williams, convinces us that ACT had not adopted a liquidation plan prior to or on the sale date of ACT's assets to JSL. During the December 18, 1989, meeting, Turner informed Briggs that minutes of a liquidation meeting were needed forPage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
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