-7- Mr. Batson prepared an appraisal report and submitted it to the Company. Mr. Batson's fee was paid by the Company and charged as compensation to Mr. Thompson. It was Mr. Thompson's understanding that both Mr. Batson and Mr. Hawkins, although formally engaged by him, were also representing his wife, here petitioner, with respect to her potential gift tax liability. In due course, petitioner and Mr. Thompson received the revenue agent's report and filed a protest. In May of 1992, Mr. Hawkins, by letter, submitted the appraisal prepared by Mr. Batson to the Appeals Office. On or about August 11, 1993, statutory notices were issued to petitioner and Mr. Thompson determining gift tax deficiencies and additions to tax under section 6660 based on respondent's valuation of the Company stock. The petition was filed on September 1, 1993. Upon the filing of respondent's answer on November 1, 1993, the case was at issue. A Notice Setting Case for Trial, dated November 5, 1993, set the case for trial on April 11, 1994, and the Standing Pre-Trial Order directed the parties to file expert witness reports no later than 30 days prior to the first day of the trial session. On or about February 16, 1994, Mr. Thompson hired attorney David Aughtry (hereinafter Mr. Aughtry) to represent Mr. Thompson and petitioner at trial. A valuation expert, Z. Christopher Mercer (hereinafter Mr. Mercer), of Mercer Capital Management,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011