- 4 -- 4 -
requested additional clarification. Receiving no response to
this letter, Mr. Berry contacted Mr. Neilson by telephone on
November 4, 1997. During this conversation, Mr. Neilson stated
that he had just received information from petitioners'
accountant tracing the liquidated funds to the Southwest account
into which they were purportedly rolled over; Mr. Neilson further
indicated that he would shortly forward this information to Mr.
Berry.
Mr. Berry did not receive the promised information from Mr.
Neilson, so he followed up with another phone call on November
26, 1997. The two agreed to meet on December 2, 1997. At the
December 2d meeting, the documentation offered by Mr. Neilson was
largely duplicative of that previously provided. Mr. Neilson
still was unable to trace the amount at issue to any combination
of deposits in the Southwest account. Mr. Neilson had not
contacted either the payor, American Express, or Southwest.
Further, Mr. Neilson presented no evidence or clarification to
establish that the $156,931 at issue had been rolled over tax-
free.
In an effort to resolve the matter, on December 3, 1997, Mr.
Berry wrote to American Express requesting that it provide
details to support the amount it had reported on the Form 1099-R,
specifically the date and amounts of the distributions, and
whether they were paid directly to Mr. Uddo or to a third party.
On January 9, 1998, Mr. Berry received a response from American
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