- 24 - which referred to petitioners collectively as "Scott", stated in pertinent part: NOW, THEREFORE, IT IS HEREBY DETERMINED AND AGREED for Federal Income Tax purposes, that: 1. The amount realized from AST upon the sale of * * * MSSTA's assets was $801,820 resulting in an additional Federal income tax liability of MSSTA in taxable year 1989 of $164,981. 2. The value of the consulting and covenant not to compete agreements between AST and Carter was $325,016. The additional amount paid to Carter of $199,984 by AST was an amount realized by MSSTA for MSSTA's assets. 3. A portion of the 12,300 shares of AST stock transferred to Scott and a portion of the consulting fee paid to Scott were amounts realized by MSSTA for MSSTA's assets. The value of the AST stock transferred and the consulting fee paid to Scott for MSSTA's assets was $199,652. 4. This agreement makes no determination with respect to whether one or more of these parties (Carter, Scott, or AST) is personally liable as a transferee for any additional Federal income tax liability of MSSTA. 5. Carter, Scott, AST, MSSTA and the Internal Revenue Service agree that in the event one or more of these parties (Carter, Scott, and/or AST) is found to be personally liable as a transferee, the liability is $164,981 plus interest from March 15, 1990. The total amount of (1) that portion of the value of the 6,150 shares of AST stock issued by AST to Mr. Scott and (2) the consulting fee paid to him, which total amount was an amount realized by MSSTA for MSSTA's assets, was $104,580. The amount of the value of that portion of the 6,150 shares of AST stockPage: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 Next
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