- 4 - In June 1983 VeloBind’s shareholders and directors approved a sale of VeloBind Junior Common Stock--Series A to Beaton, and to Steiner and the other directors of VeloBind. In 1983, Beaton bought 15,000 shares and Steiner bought 7,500 shares of Junior Common Stock--Series A. Beaton and Steiner filed timely elections under section 83(b) with respect to these purchases. Each share of Junior Common Stock--Series A carried one- sixteenth of the dividend, liquidation, and voting rights of one share of VeloBind common stock. Each share of Junior Common Stock--Series A was to convert automatically into one share of common stock if one of four specified events occurred. One of these events did occur, and the stock converted. On September 13, 1990, respondent issued notices of deficiency for 1984 to petitioners. In these notices of deficiency respondent determined that the conversion of Junior Common Stock--Series A into common stock was a taxable event that occurred in 1984. On December 12, 1990, petitioners filed petitions for 1984. On September 28, 1992, respondent issued notices of deficiency for 1985 to petitioners. In these notices of deficiency respondent determined that petitioners received additional income in the form of common stock. On December 21, 1992, petitioners filed petitions for 1985. In their petitions for 1985, petitioners assert that the period of limitations under section 6501 for assessment of tax for 1985 had expired beforePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011