- 25 -
issued by AST to Ms. Scott, which was an amount realized by MSSTA
for MSSTA's assets, was $95,072.
During April 1996, respondent's revenue officer, Linda
Wievers (Ms. Wievers), was assigned to collect MSSTA's unpaid tax
liability. Ms. Wievers followed normal collection procedures in
her attempts to collect that liability from MSSTA. Mr. Callison
informed Ms. Wievers that, as of November 27, 1996, MSSTA, a
corporation in good standing and authorized to conduct its af-
fairs within the State of Colorado, had no assets or income with
which to pay MSSTA's unpaid tax liability. In late January 1997,
Ms. Wievers concluded that MSSTA did not have any assets or in-
come with which to satisfy that liability.
On January 10, 1995, respondent issued separate notices of
transferee liability to Mr. Scott and Ms. Scott, respectively, in
which respondent determined that they are liable as transferees
of MSSTA (1) in amounts not exceeding $104,580 and $95,072, re-
spectively, for MSSTA's unpaid tax liability and (2) for interest
"as provided by law".
OPINION
We shall first address certain evidentiary matters. At
trial, we admitted into evidence conditionally, subject to our
ruling on admissibility, certain evidence to which respondent
objected.
Paragraph 25 of the stipulation (stipulation 25) states:
Page: Previous 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 NextLast modified: May 25, 2011