Joseph F. and Camille T. Uddo - Page 5

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                    Express providing a breakdown of the distributions from Mr.                                                                                            
                    Uddo's accounts by date, amount, and payee.  Due to an obvious                                                                                         
                    date error in two of the entries, Mr. Berry called American                                                                                            
                    Express to request a correction.  The corrected response was                                                                                           
                    received by Mr. Berry on January 16, 1998.                                                                                                             
                              Upon review of the documentation from American Express, Mr.                                                                                  
                    Berry concluded that $144,931 of the $156,931 had been rolled                                                                                          
                    over tax-free.  On January 16, 1998, Mr. Berry mailed the                                                                                              
                    American Express documentation to Mr. Neilson along with a letter                                                                                      
                    requesting any additional information that would support a                                                                                             
                    finding that the final $12,000 was also rolled over tax-free.                                                                                          
                              Mr. Berry spoke with Mr. Neilson by telephone on February                                                                                    
                    20, 1998, and Mr. Neilson stated that he needed to consult with                                                                                        
                    petitioners and their accountant.  Mr. Berry followed up with a                                                                                        
                    phone call to Mr. Neilson on February 25, 1998, and was advised                                                                                        
                    that Mr. Neilson had not received his clients' approval to                                                                                             
                    concede the remaining $12,000.  When Mr. Berry contacted Mr.                                                                                           
                    Neilson again on February 27, 1998, Mr. Neilson stated that he                                                                                         
                    had not received a response from petitioners' accountant.  Mr.                                                                                         
                    Berry then advised Mr. Neilson that decision documents would be                                                                                        
                    prepared reflecting the $12,000 as taxable.  The decision                                                                                              
                    document was prepared and faxed to Mr. Neilson on March 3, 1998.                                                                                       
                              At the call of the trial calendar on March 9, 1998, the                                                                                      
                    decision document executed by the parties was filed as a                                                                                               
                    stipulation of settlement.  The stipulation of settlement                                                                                              




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