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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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