Joseph F. and Camille T. Uddo - Page 4

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                    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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