- 2 -
Unless otherwise indicated, all section references are to the
Internal Revenue Code in effect for the years in issue. All Rule
references are to the Tax Court Rules of Practice and Procedure.
No party has requested a hearing on petitioners' motions.
Accordingly, we rule on petitioners' motions on the basis of the
parties' submissions and the record in this case. The underlying
issues raised in the petitions were settled by stipulations of
settlement. At the time their petitions were filed all of the
petitioners resided in the State of Illinois.
By notices of deficiency, respondent determined deficiencies
in petitioners' Federal income taxes as follows:
Year John F. & Tracy Marcus R. Davis W. Stephen A.
Ended L. Barford Messman Messman Messman
12/31/79 $ --- $ 5,981 $ --- $ ---
12/31/80 --- 7,420 3,710 1,934
12/31/81 3,254 --- 5,353 5,378
12/31/82 --- 1,715 3,556 11,625
12/31/83 419,987 418,124 424,317 413,677
12/31/84 30,084 36,139 19,327 15,911
Petitioners filed individual petitions and their cases were
consolidated.
The four equal shareholders of TMC Resources, Inc. (TMC
Resources) were Davis W. Messman, Marcus R. Messman, Stephen A.
Messman, and Tracy L. Barford (petitioners).
Prior to 1983, TMC Resources was the parent corporation of
a consolidated group of corporations and owned 100 percent of
the stock of the following corporations: RAM Drilling Company
Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011