- 23 - The Service's revenue agent auditing MSSTA's 1989 return preliminarily proposed, inter alia, that MSSTA realized $1.6 million on that sale and that MSSTA was liable for certain penalties. Attached to petitioners' 1991 return, which was filed on August 4, 1992, was a statement, entitled "DISCLOSURE STATEMENT OF TRANSACTION BETWEEN THOMAS H. AND LYNN D. SCOTT ("TAXPAYERS") AND AMERICAN SECURITIES TRANSFER, INC. ("AST")", which stated in pertinent part: On June 27, 1991, the taxpayers' 12,300 shares of common stock of AST were redeemed by the corporation, AST. * * * * * * * * * * The 12,300 shares of AST stock sold have a cost basis of $749,760. This basis represents the value assigned to AST shares as determined by the Internal Revenue Service in their examination of Mountain States Stock Transfer Agents, Inc. (MSSTA) * * * for tax year 1989. Around January or February 1992, petitioners retained J. William Callison (Mr. Callison) to represent MSSTA and themselves with respect to the Service's examination of the MSSTA trans- action. Mr. Callison participated in settlement negotiations with Service representatives regarding its examination of the MSSTA transaction. On December 23, 1994, Form 906-C, Closing Agreement on Final Determination Covering Specific Matters (closing agreement), was entered into by the Service, Mr. Carter, Mr. Scott, Ms. Scott, MSSTA, and AST. The closing agreement,Page: Previous 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 Next
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