Thomas H. Scott and Lynn D. Scott, Transferees - Page 2

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          spectively, for MSSTA's unpaid Federal income tax (tax) liability           
          for 1989 of $164,981 (MSSTA's unpaid tax liability) and (2) for             
          "interest as provided by law".1                                             
               We must decide whether Mr. Scott and Ms. Scott (collec-                
          tively, the Scotts) are liable as transferees of MSSTA in amounts           
          not exceeding $104,580 and $95,072, respectively, for MSSTA's               
          unpaid tax liability and, if so, whether they are liable for                
          interest on such respective amounts from March 15, 1990, the date           
          on which MSSTA's unpaid tax liability became due, to January 10,            
          1995, the date on which the notices were issued.2  We hold that             
          Mr. Scott is so liable and that Ms. Scott is not.                           
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found                
          unless otherwise stated herein.                                             
               At the time the petition was filed, petitioners resided in             
          Denver, Colorado.                                                           
               On October 2, 1980, MSSTA was incorporated under the laws of           
          the State of Colorado.  From its incorporation until September              

          1  Unless otherwise indicated, all section references are to the            
          Internal Revenue Code (Code) in effect for the years at issue,              
          and all Rule references are to the Tax Court Rules of Practice              
          and Procedure.                                                              
          2  The parties agree that in the event the Court were to deter-             
          mine that either petitioner is liable as a transferee of MSSTA,             
          each such petitioner also would be liable under secs. 6601 and              
          6621 for interest from Jan. 10, 1995, to the date on which the              
          amount of each such petitioner's liability is paid.                         

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