Reed Smith Shaw & MClay, William J. Smith, Tax Matters Partner - Page 23

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             fraudulently or criminally.  Of course, we are not required              
             to accept the self-serving testimony of an interested                    
             witness.  Tokarski v. Commissioner, 87 T.C. 74, 77 (1986);               
             cf. Jones v. Commissioner, T.C. Memo. 1997-368.  In this                 
             case, we do not credit Mr. Stein's testimony on this point.              
                  The principal argument of the tax matters partner is                
             that execution of the contribution agreement and                         
             ratification by themselves constituted an assignment by                  
             Mr. Stein and his wife of "all of their right, title and                 
             interest in and to 2,000 shares of Saztec to Petitioner."                
             The tax matters partner further describes the contribution               
             agreement as "an immediate assignment of all of                          
             Petitioner's right, title and interest in those shares"                  
             to the trustee of the subject defined benefit plan.                      
                  The tax matters partner notes that the 2,000 shares                 
             of Saztec stock were held in "street name" in the Steins'                
             account and argues that execution of the contribution                    
             agreement was the only act required to transfer ownership                
             of the stock from Mr. and Mrs. Stein to the partnership and              
             from the partnership to the trust.  He further argues that,              
             after the contribution agreement was executed, the Saztec                
             stock was placed irrevocably beyond Mr. Stein's personal                 
             control, and any action by Mr. Stein with respect to the                 








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