Thomas H. Scott and Lynn D. Scott, Transferees - Page 25

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          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".                                                       
               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               
               Paragraph 25 of the stipulation (stipulation 25) states:               

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